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Penn. Mutual Life Ins. Co. v. Comm'r

32 B.T.A. 839 (B.T.A. 1935)
Penn. Mutual Life Ins. Co. v. Comm'r

10 Cited authorities

  1. New Colonial Co. v. Helvering

    292 U.S. 435 (1934)   Cited 1,660 times   19 Legal Analyses
    In New Colonial Ice Co. v. Helvering, 292 U.S. 435, 54 S. Ct. 788, 791, 78 L. Ed. 1348, the court said: "As a general rule a corporation and its stockholders are deemed separate entities and this is true in respect of tax problems."

  2. Ilfeld Co. v. Hernandez

    292 U.S. 62 (1934)   Cited 113 times
    In Ilfeld the taxpayer had taken deductions, through consolidated returns, for the annual losses of its subsidiaries; when the subsidiaries' assets were sold and the companies dissolved, the parent taxpayer sought to take deductions for losses of its investment in the subsidiaries.

  3. Helvering v. Ind. Life Ins. Co.

    292 U.S. 371 (1934)   Cited 62 times   1 Legal Analyses
    In Helvering v. Independent Life Insurance Co., 292 U.S. 371 (1934) the Supreme Court clearly stated, in the case of an insurance company taxpayer, that the mere rental value of a building used by the owner does not constitute income within the meaning of the 16th amendment, citing Eisner v. Macomber, supra, and that a tax on such value as income would be a direct tax requiring apportionment, citing Pollock and a number of subsequent decisions.

  4. Helvering v. Insurance Co.

    294 U.S. 686 (1935)   Cited 56 times
    Holding that deductions must be plainly authorized, not derived from ambiguities

  5. Rockford Life Ins. Co. v. Comm'r

    292 U.S. 382 (1934)   Cited 18 times

    CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE SEVENTH CIRCUIT. No. 722. Argued April 4, 1934. Decided May 21, 1934. 1. Under the Revenue Act of 1928 a life insurance company is not allowed to deduct from gross income the expenses of a building owned and occupied in whole or in part by it unless there is included in the return of gross income the rental value of the space so occupied, not less than a sum which, in addition to any rents received from other tenants, shall provide a net income,

  6. Duffy v. Mutual Benefit Co.

    272 U.S. 613 (1926)   Cited 20 times

    CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE THIRD CIRCUIT. No. 108. Argued October 21, 22, 1926. Decided November 29, 1926. 1. The legal reserve of a mutual life insurance company, consisting of premiums paid by the members, and earnings upon premiums invested, is "invested capital," within the war excess profits tax provisions of the Revenue Act of 1917, which (§ 207(a),) define invested capital, in the case of a corporation or partnership, as "(1) Actual cash paid in, (2) the actual cash

  7. Taff v. Smith

    114 S.C. 306 (S.C. 1920)   Cited 43 times
    Holding the beneficiary holds a vested interest in a life insurance policy

  8. Continental Assur. Co. v. United States, (1934)

    8 F. Supp. 474 (Fed. Cl. 1934)   Cited 11 times

    No. 42523. October 15, 1934. Jay C. Halls, of Chicago, Ill. (Albert L. Hopkins, Stephen M. Reynolds, and Hopkins, Sutter, Halls De Wolfe, all of Chicago, Ill., on the brief), for plaintiff. Guy Patten and Edward H. Horton, both of Washington, D.C., and Frank J. Wideman, Asst. Atty. Gen., for the United States. Before BOOTH, Chief Justice, and GREEN, LITTLETON, WILLIAMS, and WHALEY, Judges. LITTLETON, Judge. The question presented in this case is whether the amounts of $107,620 and $127,407.73 held

  9. City of Perry v. Johnson

    233 P. 679 (Okla. 1925)   Cited 12 times

    No. 15217 Opinion Filed January 27, 1925. Municipal Corporations — Constitutional "Debt Limit" — Special Assessments Against City Property for Improvements. Section 26, art, 10, of the state Constitution is a "debt" limit and not a "tax" limit provision, and does not apply to assessments for benefits occasioned by reason of public improvements levied against real estate owned by a municipal corporation. (Syllabus by Ray, C.) Commissioners' Opinion, Division No. 1. Error from District Court, Noble

  10. Matter of Rapid Transit Commissioners

    23 A.D. 472 (N.Y. App. Div. 1897)

    December Term, 1897. Albert B. Boardman and Edward M. Shepard, for the motion. George Zabriskie and Cephas Brainerd, Jr., opposed. VAN BRUNT, P.J.: The imperious necessity of improved means of transit in the city of New York has long been recognized. It had become so evident that in the year 1892 the people determined that, as there seemed to be no other means for its accomplishment, it should be brought into existence even by the pledge of the credit of the city. This necessity seems to have addressed