BROOKS

v.

MISSISSIPPI; AND BROOKS V. MISSISSIPPI

Citator

Cited By

• The W. Cas. & Sur. Co. v. Commissioner OF Internal Revenue, 571 F.2d 514 (10th Cir. 1978)
  …te and that where they conflict with the ordinary requirements of § 162, the latter prevails. The position of the Commissioner and of the Tax Court is supported by Commissioner v. General Reinsurance Corp., 190 F. 2d 148 (2d Cir.), cert. dismissed, 342 U.S. 863, 72 S.Ct. 111, 96 L.Ed. 649 (1951). In that case the court was construing § 204(b)(1) of the 1939 Internal Revenue Code, which was identical in pertinent part to the present § 832(b)(1) and which required gross income to be “computed on the basis of…
• Gerling Int'l Ins. Co. v. Comm'r of Internal Revenue. Appeal of Gerling Int'l Ins. Co., 839 F.2d 131 (3d Cir. 1988)
  …ance company could not under principles of § 162 include as deductions certain commissions not yet paid or incurred, although NAIC form would have allowed); Commissioner v. General Reinsurance Corp., 190 F. 2d 148, 151 (2d Cir.1951), cert. dismissed 342 U.S. 863, 72 S.Ct. 111, 96 L.Ed. 649 (1951), and its companion case Commissioner v. United States Guarantee Co., 190 F. 2d 152 (2d Cir.1951) (requiring method of timing deductions that would more closely reflect when losses were actually paid than method spe…
• The Home Grp., Inc. v. Commissioner OF Internal Revenue, 875 F.2d 377 (2d Cir. 1989)
  …Code relating to property and casualty insurance companies demonstrates only that the Statutory Method was to be used as the starting point for tax accounting. Commissioner v. General Reinsurance Corp., 190 F. 2d 148, 151 (2 Cir.), cert. dismissed, 342 U.S. 863 (1951). As stated in Western Casualty, supra, the Statutory Method thus is not absolute. Western Casualty, supra, 571 F. 2d at 517; see also General Reinsurance, supra, 190 F. 2d at 150-51 (statute prevails over Statutory Method where the two conf…