United States Tax Court April 23, 1970, Docket No. 1379-68 (Modern Home Fire & Casualty Ins. Co. v. Commissioner)

lead-opinion

OPINION

Issue 1.- — Taxability of Premium Reserve

The petitioner contends that 15 percent of the premiums received on account of writing title insurance should properly be excluded or deducted from gross income as “unearned premiums” within the meaning of section 832 (b) (4). That section provides, in part, as follows:

(4) PREMIUMS earned.