Legal Opinion
City Title Ins. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 3, 1946No. 18PublishedCited by 6 opinions
1Opinion of the Court
FRANK, Circuit Judge.
The revenue statute expressly provides, in sections 202 and 203, 26 U.S.C.A. Int. Rev.Code, that, as to certain insurance companies, percentages of certain reserve funds, including some required by a state statute, may be deducted from gross income. No similar deduction is referred to in § 204, which governs here. Consequently, the existence of a reserve or the mere fact that it was required by a state statute, cannot justify the deduction taxpayer claimed. The sole issue here, then, is whether the sums set apart in the reserve are “unearned premiums.”
The Commissioner…
2Cases cited5 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Equitable Life Assurance Society v. CommissionerSupreme Court of the United States · 1944
- American Title Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1935
- Early v. Lawyers Title Ins. CorporationCourt of Appeals for the Fourth Circuit · 1942
3Cited by6 opinions
- Title & Trust Co. v. United StatesDistrict Court, M.D. Florida · 1965
- Modern Home Fire & Casualty Ins. Co. v. CommissionerUnited States Tax Court · 1970
- Houston Title Guaranty Co. v. CommissionerUnited States Tax Court · 1954
- Washington Title Insurance v. United StatesUnited States Court of Claims · 1955
- Houston Title Guaranty Co. v. CommissionerUnited States Tax Court · 1954
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