Title & Trust Co. v. Commissioner
United States Tax Court
Held, petitioner, a Florida title insurance company, is entitled to deduct at the end of 1965, as unearned premiums on outstanding business within the meaning of sec. 832(b)(4), I.R.C. 1954, the amount of an unearned-premium reserve required by Florida law to be established in prior years but first required by Florida law to be returned to income by an amendment to the Florida statute enacted in 1965.
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined deficiencies in petitioner’s income taxes for the taxable years 1962,1963, and 1964, in the amounts of $58,103.84, $8,381.01, and $8,587.10, respectively. The issue for decision is whether petitioner is entitled to deduct from its underwriting income in the year 1965 the total unearned-premium reserve accumulated on its books during the years 1959 through 1964 and carry back to the years 1962 through 1964 the net operating loss created by that deduction. In the alternative, petitioner contends that it is entitled to deduct the unearned-premium reserve…
2Cases cited9 opinions
- Daniel v. Florida State Turnpike AuthoritySupreme Court of Florida · 1968
- Bituminous Casualty Corp. v. CommissionerUnited States Tax Court · 1971
- Bay National Bank and Trust Company v. DickinsonDistrict Court of Appeal of Florida · 1969
- Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
- Early v. Lawyers Title Ins. CorporationCourt of Appeals for the Fourth Circuit · 1942
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3Cited by2 opinions
- Medical Defense Associates, Ltd. v. CommissionerUnited States Tax Court · 1984
- Title & Trust Co. v. CommissionerUnited States Tax Court · 1972