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FEDERAL UNION INSURANCE CO. v. COMMISSIONER

Docket No. 3968.

5 T.C. 374 (1945)

FEDERAL UNION INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1945.

Attorney(s) appearing for the Case

John S. Breckinridge, Esq., for the petitioner.

Laurence F. Casey, Esq., for the respondent.

The Commissioner determined a deficiency in excess profits tax for the year 1940 in the amount of $756.66. The questions presented for our determination are (1) whether petitioner's unearned premium reserve on fire and marine insurance is a part of its equity invested capital within the meaning of section 718 of the Internal Revenue Code and (2) whether petitioner's reinsurance recoverable on unpaid losses and its unearned premiums on reinsurance in force are admissible assets...

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