Cuesta Title Guaranty Co. v. Commissioner
United States Tax Court
Petitioner was engaged in the business of examining land titles and offering title insurance service as an underwritten title company pursuant to California law. Petitioner established reserves for unearned premiums and reserves for unpaid losses, computed in accordance with reserve requirements applicable under California law to a title insurer.
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Petitioner was engaged in the business of examining land titles and offering title insurance service as an underwritten title company pursuant to California law. Petitioner established reserves for unearned premiums and reserves for unpaid losses, computed in accordance with reserve requirements applicable under California law to a title insurer. Held, since petitioner does not bear the economic risk of loss on the insurance contracts issued, it is not an insurance company taxable under sec. 831, I.R.C. 1954, and thus is not entitled to deductions for its reserves for losses.
1Opinion of the Court
Cuesta Title Guaranty Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Cuesta Title Guaranty Co. v. Commissioner
Docket No. 7993-75
United States Tax Court
71 T.C. 278; 1978 U.S. Tax Ct. LEXIS 24;
November 22, 1978, Filed
Decision will be entered for the respondent.
Petitioner was engaged in the business of examining land titles and offering title insurance service as an underwritten title company pursuant to California law. Petitioner established reserves for unearned premiums and reserves for unpaid losses, computed in accordance with reserve requirements applicable under…
2Cases cited15 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Brown v. HelveringSupreme Court of the United States · 1934
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Bowers v. Lawyers Mortgage Co.Supreme Court of the United States · 1932
- United States v. Cambridge Loan & Building Co.Supreme Court of the United States · 1928
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