Title & Trust Company of Florida v. United States

The sole issue in this case is whether Section 832(b) (4) of the Internal Revenue Code permits the taxpayer, the appellant corporation, to deduct from its taxable income the “reserve for unearned income” established by it pursuant to the mandatory requirements of Section 625.111 of the Florida Statutes.

Both parties filed motions for summary judgment.

During the years in question the taxpayer failed to segregate the amount of reserve from its general funds and to make the appropriate accounting entries in its books.

In a well reasoned opinion, reported at 243 F.Supp. 42 (M.D.Fla.1965), the…