Great American Indem. Co. v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Abnormal Deduction -- Surety Loss -- Class -- Section 711 (b) (1) (J) (i) and (ii). -- A deduction taken in 1939 for an anticipated loss on a surety bond was not a separate class and abnormal within section 711 (b) (1) (J) (i) and the surety code number under which it was classified did not represent a class of deductions for the purpose of section 711 (b) (1) (J) (ii). 2. Excess Profits Tax -- Exclusion of Income of Taxable Year -- Section 711 (a)…
Read the full summary
1. Excess Profits Tax -- Abnormal Deduction -- Surety Loss -- Class -- Section 711 (b) (1) (J) (i) and (ii). -- A deduction taken in 1939 for an anticipated loss on a surety bond was not a separate class and abnormal within section 711 (b) (1) (J) (i) and the surety code number under which it was classified did not represent a class of deductions for the purpose of section 711 (b) (1) (J) (ii). 2. Excess Profits Tax -- Exclusion of Income of Taxable Year -- Section 711 (a) (1) (E). -- Salvage recovered by a surety after paying claims of insured is not recovery of bad debts within the meaning…
1Opinion of the Court
OPINION.
Murdock, Judge:
Insurance companies, other than life or mutual, are taxed in accordance with the special provisions of section 204. One of the deductions allowed is for losses incurred as defined in subsection (b) (6). That subsection is as follows:
Losses Inoubeed. — “Losses incurred” means losses incurred during the taxable year on insurance contracts, computed as follows:
To losses paid during the taxable year, add salvage and reinsurance recoverable outstanding at the end of the preceding taxable year, and deduct salvage and reinsurance recoverable outstanding at the end of the…
2Cases cited2 opinions
- Biddle v. CommissionerUnited States Tax Court · 1948
- Beneficial Industrial Loan Corp. v. CommissionerUnited States Tax Court · 1946
3Cited by8 opinions
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- United States Steel Corp. v. United StatesDistrict Court, S.D. New York · 1970
- Quaker Oats Co. v. CommissionerUnited States Tax Court · 1957
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- Great American Indem. Co. v. CommissionerUnited States Tax Court · 1952
3 more not listed; retrieve them via the Exa API.