R.V.I. Guar. Co. v. Comm'r
United States Tax Court
P sold contracts for which the company's name is an acronym--"residual value insurance." The parties insured under these contracts included leasing companies, manufacturers, and financial institutions. The assets insured included passenger vehicles, commercial real estate, and commercial equipment. The insured parties were the lessors of these assets or provided financing for such leases.
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P sold contracts for which the company's name is an acronym--"residual value insurance." The parties insured under these contracts included leasing companies, manufacturers, and financial institutions. The assets insured included passenger vehicles, commercial real estate, and commercial equipment. The insured parties were the lessors of these assets or provided financing for such leases. When pricing a lease, a lessor must estimate what residual value the asset will have when it is returned to him at the end of the lease. P insured against the risk that the actual value of the asset upon…
1Opinion of the Court
R.V.I. GUARANTY CO., LTD. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
R.V.I. Guar. Co. v. Comm'r
Docket No. 27319-12.
United States Tax Court
145 T.C. 209; 2015 U.S. Tax Ct. LEXIS 39; 145 T.C. No. 9;
September 21, 2015, Filed
Decision will be entered under Rule 155.
P sold contracts for which the company's name is an acronym--"residual value insurance." The parties insured under these contracts
included leasing companies, manufacturers, and financial institutions. The assets insured included passenger vehicles, commercial real estate, and commercial equipment. The…
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