Legal Opinion

Pacific Employers Ins. v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided March 29, 1937No. 8166PublishedCited by 18 opinions

1Opinion of the Court

HANEY, Circuit Judge.

To review a decision of the Board of Tax Appeals this petition is presented to us.

Petitioner, a California corporation, has been, and is operating an insurance business solely in California. Fourteen-fifteenths of the net premium income of petitioner for the year 1930 was from workmen’s compensation insurance, and the balance was from automobile liability, collision and property damage insurance, principally, and a small volume from public liability and theft insurance.

Section 204 of the Revenue Act of 1928 (26 U.S.C.A. § 204 and note) is applicable to petitioner in the…

2Cases cited2 opinions

  1. Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
  2. Murphy Oil Co. v. BurnetCourt of Appeals for the Ninth Circuit · 1932

3Cited by18 opinions

  1. Bituminous Casualty Corp. v. CommissionerUnited States Tax Court · 1971
  2. Hanover Ins. Co. v. CommissionerUnited States Tax Court · 1976
  3. Commissioner of Internal Revenue v. General Reinsurance CorpCourt of Appeals for the Second Circuit · 1951
  4. Harco Holdings, Incorporated, and Subsidiaries v. United StatesCourt of Appeals for the Seventh Circuit · 1992
  5. Cramp Shipbuilding Co. v. CommissionerUnited States Tax Court · 1951

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