Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
United States Tax Court
Held: 1. An unincorporated mutual marine insurance association which keeps its books and files its Federal income tax returns on an accrual basis is entitled to deduct dividends declared in the year so declared to the extent of the indebtedness thus created to its policyholders even though a part of the dividend is contributed by such policyholder to the association for a recognized interest represented by such contribution, but is not entitled to deduct amounts withheld as…
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Held: 1. An unincorporated mutual marine insurance association which keeps its books and files its Federal income tax returns on an accrual basis is entitled to deduct dividends declared in the year so declared to the extent of the indebtedness thus created to its policyholders even though a part of the dividend is contributed by such policyholder to the association for a recognized interest represented by such contribution, but is not entitled to deduct amounts withheld as loss retentions under a preexisting resolution with no interest in such retention remaining in the policyholders. 2.…
1Opinion of the Court
Commercial Fishermen's Inter-Insurance Exchange, Petitioner, v. Commissioner of Internal Revenue, Respondent
Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
Docket No. 74289
United States Tax Court
38 T.C. 915; 1962 U.S. Tax Ct. LEXIS 73;
September 21, 1962, Filed
Decision will be entered under Rule 50.
Held: 1. An unincorporated mutual marine insurance association which keeps its books and files its Federal income tax returns on an accrual basis is entitled to deduct dividends declared in the year so declared to the extent of the indebtedness thus created to its policyholders even…
2Cases cited15 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- General American Investors Co. v. CommissionerSupreme Court of the United States · 1955
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- American Equitable Assur. Co. of New York v. HelveringCourt of Appeals for the Second Circuit · 1933
- Abraham Teitelbaum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
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