Legal Opinion

Title & Trust Co. v. Commissioner

United States Tax Court

Decided August 28, 1972No. Docket No. 749-68Published

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

Title & Trust Company of Florida, Petitioner v. Commissioner of Internal Revenue, Respondent

Title & Trust Co. v. Commissioner

Docket No. 749-68

United States Tax Court

58 T.C. 900; 1972 U.S. Tax Ct. LEXIS 66;

August 28, 1972, Filed

Decision will be entered for petitioner.

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…

2Cases cited10 opinions

  1. Daniel v. Florida State Turnpike AuthoritySupreme Court of Florida · 1968
  2. Bituminous Casualty Corp. v. CommissionerUnited States Tax Court · 1971
  3. Bay National Bank and Trust Company v. DickinsonDistrict Court of Appeal of Florida · 1969
  4. Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
  5. Early v. Lawyers Title Ins. CorporationCourt of Appeals for the Fourth Circuit · 1942

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