Bay Counties Title Guaranty Co. v. Commissioner
United States Tax Court
Petitioner is an underwritten title and controlled escrow company engaged in the business of making abstracts of titles. It had an established title plant prior to 1952 which was its chief capital asset. Since petitioner started business it has followed the practice of acquiring for a consideration from others each year a substantial number of previously prepared title reports showing the status of titles to pieces of property up to some date prior to petitioner's purchase.
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Petitioner is an underwritten title and controlled escrow company engaged in the business of making abstracts of titles. It had an established title plant prior to 1952 which was its chief capital asset. Since petitioner started business it has followed the practice of acquiring for a consideration from others each year a substantial number of previously prepared title reports showing the status of titles to pieces of property up to some date prior to petitioner's purchase. Most of such title reports were filed in petitioner's records for use in subsequent years depending on when the…
1Opinion of the Court
Bay Counties Title Guaranty Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Bay Counties Title Guaranty Co. v. Commissioner
Docket No. 63623
United States Tax Court
34 T.C. 29; 1960 U.S. Tax Ct. LEXIS 177;
April 12, 1960, Filed
Decision will be entered for the respondent.
Petitioner is an underwritten title and controlled escrow company engaged in the business of making abstracts of titles. It had an established title plant prior to 1952 which was its chief capital asset. Since petitioner started business it has followed the practice of acquiring for a consideration from others…
2Cases cited11 opinions
- Hotel Kingkade v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
- Consolidated Apparel Co. v. CommissionerUnited States Tax Court · 1952
- Consolidated Apparel Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
- Russell Box Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Appeal of First National Bank of St. LouisUnited States Board of Tax Appeals · 1926
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