New Hampshire Fire Ins. Co. v. Commissioner
United States Tax Court
1. Petitioners, fire insurance companies incorporated under the laws of New Hampshire and doing business in that state, reinsured a portion of their risks in companies not admitted to do business in New Hampshire.
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1. Petitioners, fire insurance companies incorporated under the laws of New Hampshire and doing business in that state, reinsured a portion of their risks in companies not admitted to do business in New Hampshire. In making the annual report of their operations and condition to the Insurance Commissioner of the State of New Hampshire, petitioners used the Convention Form as required by the Insurance Commissioner and as accepted and followed uniformly throughout the United States. The Convention Form does not recognize transactions with unadmitted companies, nor does the Insurance Commissioner…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The major issue presents a question that, so far as we can discover, has never been answered judicially. It is, in essence, whether, under the provisions of section 204 (b) of the Kevenue Acts of 1936 and 1938, the statutory standard (the Convention Form), universally long accepted and established throughout the United States, which does not recognize transactions with unadmitted companies, shall govern the computation of income of insurance companies other than life or mutual, or whether the entire business done by such companies, including transactions with…
2Cases cited6 opinions
- Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
- O'Hara v. Luckenbach Steamship Co.Supreme Court of the United States · 1926
- Maddock v. MagoneSupreme Court of the United States · 1894
- Sonn v. MagoneSupreme Court of the United States · 1895
1 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Jordan v. CommissionerUnited States Tax Court · 1973
- Commissioner of Internal Revenue v. General Reinsurance CorpCourt of Appeals for the Second Circuit · 1951
- Columbus & Southern Ohio Electric Co. v. CommissionerUnited States Tax Court · 1956
- Pacific Ins. Co., Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1951
- Lanteen Medical Laboratories, Inc. v. CommissionerUnited States Tax Court · 1948
10 more not listed; retrieve them via the Exa API.