Hanover Ins. Co. v. Commissioner
United States Tax Court
Petitioner's predecessor, a casualty insurance company, reflected its income on its returns substantially on the basis of the underwriting exhibit of the annual statement approved by the National Association of Insurance Commissioners.
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Petitioner's predecessor, a casualty insurance company, reflected its income on its returns substantially on the basis of the underwriting exhibit of the annual statement approved by the National Association of Insurance Commissioners. Respondent adjusted the estimated figures for "unpaid losses" and "expenses unpaid," as shown on such returns and underwriting exhibit, under the "fair and reasonable estimate" test embodied in the predecessor to sec. 1.832-4(b), Income Tax Regs. Petitioner sought summary judgment on the grounds that sec. 832(b)(1), I.R.C. 1954, automatically precludes…
1Opinion of the Court
Hanover Insurance Company Successor in Interest to: Massachusetts Bonding and Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Hanover Ins. Co. v. Commissioner
Docket No. 1557-71
United States Tax Court
65 T.C. 715; 1976 U.S. Tax Ct. LEXIS 180;
January 7, 1976, Filed
Petitioner's predecessor, a casualty insurance company, reflected its income on its returns substantially on the basis of the underwriting exhibit of the annual statement approved by the National Association of Insurance Commissioners. Respondent adjusted the estimated figures for "unpaid losses" and…
2Cases cited28 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- United States v. South-Eastern Underwriters Assn.Supreme Court of the United States · 1944
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Steward MacHine Co. v. DavisSupreme Court of the United States · 1937
- United States v. CorrellSupreme Court of the United States · 1967
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