Specialized Services, Inc. v. Commissioner
United States Tax Court
Superior, a subsidiary corporation of petitioner, operates as a motor vehicle common carrier. Superior carries liability insurance for financial protection against the risk of bodily injury to employees and third parties, as well as the risk of damage to cargo and other property which would arise as a result of vehicular accidents occurring during the normal business operations. As of Sept. 1, 1976, the insurance policy provided for a $ 50,000 deductible.
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Superior, a subsidiary corporation of petitioner, operates as a motor vehicle common carrier. Superior carries liability insurance for financial protection against the risk of bodily injury to employees and third parties, as well as the risk of damage to cargo and other property which would arise as a result of vehicular accidents occurring during the normal business operations. As of Sept. 1, 1976, the insurance policy provided for a $ 50,000 deductible. On that same date Superior, the insurer, and a bank executed a Loss Fund Agreement which specified that any funds placed on deposit into an…
1Opinion of the Court
Specialized Services, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Specialized Services, Inc. v. Commissioner
Docket No. 17054-79
United States Tax Court
77 T.C. 490; 1981 U.S. Tax Ct. LEXIS 69;
August 25, 1981, Filed
Decision will be entered for the respondent.
Superior, a subsidiary corporation of petitioner, operates as a motor vehicle common carrier. Superior carries liability insurance for financial protection against the risk of bodily injury to employees and third parties, as well as the risk of damage to cargo and other property which would arise as a result of vehicular…
2Cases cited5 opinions
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- Poirier & McLane Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Poirier & McLane Corp. v. CommissionerUnited States Tax Court · 1975
- Lummus Supply Co. v. Fidelity Federal Savings & Loan Ass'nCourt of Appeals of Georgia · 1977
- Specialized Services, Inc. v. CommissionerUnited States Tax Court · 1981