United States v. Weber Paper Company

320 F.2d 199, 12 A.F.T.R.2d (RIA) 5256, 1963 U.S. App. LEXIS 4524
CourtCourt of Appeals for the Eighth Circuit
DecidedJuly 26, 1963
Docket17162_1
StatusPublished
Cited by16 cases

This text of 320 F.2d 199 (United States v. Weber Paper Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Weber Paper Company, 320 F.2d 199, 12 A.F.T.R.2d (RIA) 5256, 1963 U.S. App. LEXIS 4524 (8th Cir. 1963).

Opinion

SANBORN, Circuit Judge.

This is an appeal by the United States from a judgment for a taxpayer (appel-lee) in an action for the refund of corporate income tax deficiencies alleged to have been erroneously assessed and collected for the calendar years 1956, 1957 and 1958. The action was brought after timely claims for refund had been denied. The deficiency in each of the years was based upon the disallowance by the Commissioner of Internal Revenue of the major portion of a deduction taken by the taxpayer of an amount claimed by it to be a premium paid for flood insurance coverage on its business property, and therefore deductible as a business expense under Section 162(a) of the Internal Revenue Code of 1954, 26 U.S.C. 1958 ed. § 162(a), 1 and Treasury Regulations. 2

The evidentiary facts out of which this controversy arose are not in dispute. The sole issue was and is that of the deducti-bility under § 162(a) of the amounts paid as premium deposits to National Flood Underwriters, a reciprocal or inter-insurance exchange, for flood insurance. The trial court’s detailed Findings of Fact and Conclusions of Law are published in 204 F.Supp. 394. They sustain the judgment appealed from. The Government does not challenge the court’s findings of the basic facts, but contends that the judgment is based upon a misapplication of the law to such facts.

The taxpayer, as its name indicates, is a dealer in paper and paper products. It is located in a rented building in a low-lying area in Kansas City, Missouri, near the confluence of the Kansas (Kaw) and Missouri rivers. The area, known as Central Industrial District, was seriously inundated in the floods of 1903 and 1951. *201 In the flood of 1951, damage to the inventory of the taxpayer amounted to $90,000. As a result of the serious flood losses suffered by the taxpayer and others, a demand for flood insurance protection arose. None was available. Existing insurance carriers concluded that such risks could not soundly be underwritten, due to their nature and the limited demand for such insurance. Congress undertook to solve the problem by enactment of the Federal Flood Insurance Act of 1956, 70 Stat. 1078, 42 U.S.C. 1958 ed. § 2401 et seq. This Act contemplated federal and state participation in providing for the necessary reserves. Nothing came of it.

Finally it was suggested by a Kansas City Chamber of Commerce group that flood insurance might be furnished under a reciprocal or inter-insurance plan to be financed by those exposed to the risk of flood damage. The National Flood Under-writers (National) was organized under the laws of Missouri relating to reciprocals or inter-insurance exchanges. 3 19 V.A.M.S. §§ 375.790 to 375.920. National was, m July of 1957, authorized by the State of Missouri to write fire, allied lines, and flood insurance on the reciprocal or inter-insurance plan. In 1958 it was similarly licensed by the State of Kansas. Flood Insurance Associates, Inc., a Missouri corporation organized in December 1955, was designated Attorney-in-Fact for the subscribers for insurance in National, of which there were a substantial number, including the taxpayer.

Prior to the organization of National Flood Underwriters, Mr. John B. Gage— one of the counsel for the appellee in this case — as attorney for the Wilweb Investment Company, which owns the building occupied by the taxpayer, undertook to procure a ruling from the Commissioner of Internal Revenue as to whether annual premium deposits proposed to be made by Wilweb, a subscriber to the inter-insurance plan, would be deductible as a business expense under the Internal Revenue Code. The response of the Commissioner, dated July 24,1956, is set forth in the margin. 4 A similar *202 ruling was obtained by the Real Estate Corporation, Inc., of Kansas City, Kansas, another subscriber, by letter dated January 27, 1958. By a letter of June 15, 1959, from the United States Treasury Department, Senator Byrd, Chairman of the Committee on Finance of the United States Senate, was advised that proposed legislation to amend § 162 of the Code so as to expressly provide that “amounts paid or accrued for premiums for insurance against losses arising from floods” were deductible under that section, was unnecessary, since “the existing statute and the regulations issued thereunder appear to be sufficiently clear with respect to the deductibility of premiums paid for flood insurance.”

On June 20, 1956, the taxpayer made application to National “for $100,000 of flood insurance to be written over a ten year period, 10%, or $10,000, to become effective when policy is issued and delivered,” and at the same time executed a “Subscriber’s Agreement” with National, appointing Flood Insurance Associates, Inc., as the taxpayer’s attomey-in-fact to exchange insurance with other subscribers against flood losses. The taxpayer tendered $1,000 with the application, being 10% of the first annual premium deposit required. The balance of the $10,000 premium deposit was paid when National had been licensed to write flood insurance and had issued Policy No. 102 to the taxpayer. In August 1958 an additional $10,000 premium deposit was made by the taxpayer, thereby increasing the flood insurance coverage under Policy No. 102 to $20,000.

The Superintendent of the Insurance Division of the State of Missouri required the constant maintenance of reserves against flood insurance losses underwritten by National, equal to the face amount of all flood policies in force. This requirement was imposed because of the nature of the risk involved. The entire premium deposit of a subscriber was required to be credited on the books of National to the Catastrophe Loss Account of the individual subscriber. This account was subject to pro-rata charges for flood losses, if any. The attorney-in-fact debited the account with an amount equal to 1% of the insurance coverage. This amount was referred to in the Subscriber’s Agreement as credited to annual premium and was a General Reserve Fund which was subject to being used in payment of losses if the Catastrophe Loss Account became exhausted.

Net credits in the Catastrophe Loss Account and the General Reserve Fund were to be invested by the Attorney-in-Fact as directed by an Investment Committee appointed by an Advisory Committee selected by the subscribers and the Attorney-in-Fact, so as to produce investment income. Investment earnings *203 at the end of each fiscal year were to be credited to the Catastrophe Loss Account and the General Reserve Fund, but were subject to deduction for the expenses of operation of National and the compensation of the Attorney-in-Fact. During the years in suit there were no investment earnings to be credited to the account of the taxpayer.

The flood risk assumed by National was not reinsured. No reinsurance was available. No flood losses were incurred during the taxable years in suit nor have any occurred since.

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Bluebook (online)
320 F.2d 199, 12 A.F.T.R.2d (RIA) 5256, 1963 U.S. App. LEXIS 4524, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-weber-paper-company-ca8-1963.