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WESTERN CAS. & SUR. CO. v. C. I. R.

No. 76-1631.

571 F.2d 514 (1978)

The WESTERN CASUALTY AND SURETY COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, American Insurance Association, American Mutual Insurance Alliance, and National Association of Independent Insurers, Amici Curiae.

United States Court of Appeals, Tenth Circuit.

Decided January 31, 1978.

Rehearing Denied March 13, 1978.

Attorney(s) appearing for the Case

Reece A. Gardner of Stinson, Mag, Thomson, McEvers & Frizzell, Kansas City, Mo., for petitioner-appellant.

Richard W. Perkins, Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., and Gilbert E. Andrews, Tax Div., Dept. of Justice, Washington, D. C., on the brief), for respondent-appellee.

John S. Breckinridge, Jr. of Everett, Johnson & Breckinridge, New York City (K. Martin Worthy and Arthur Peter, Jr. of Hamel, Park, McCabe & Saunders, Washington, D. C., Charles W. Davis, Frederic W. Hickman and Richard Bromley of Hopkins, Sutter, Mulroy, Davis & Cromartie, Chicago, Ill., on the brief), for amici curiae.

Before McWILLIAMS, BARRETT and DOYLE, Circuit Judges.

WILLIAM E. DOYLE, Circuit Judge.

We here review a decision of the Tax Court which upheld in part the Commissioner's determination of deficiencies in the Western Casualty and Surety Company's income tax for the taxable years 1967, 1968 and 1969. The basic issue is one of income tax law as it pertains to a fire and casualty insurance company. We must determine whether the petitioner was entitled to include as deductions commissions on deferred premium installments,...

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