Standard Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. In the determination of the "invested assets" of a life insurance company under section 245(a)(5) of the Revenue Act of 1921, real estate should be included at its book value less an outstanding mortgage, and appreciation in value not shown upon the taxpayer's books but reported in the convention form of life insurance companies to state insurance departments as nonledger assets may not be included. 2. A tax on capital stock "of all kinds, including common, special, and…
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1. In the determination of the "invested assets" of a life insurance company under section 245(a)(5) of the Revenue Act of 1921, real estate should be included at its book value less an outstanding mortgage, and appreciation in value not shown upon the taxpayer's books but reported in the convention form of life insurance companies to state insurance departments as nonledger assets may not be included. 2. A tax on capital stock "of all kinds, including common, special, and preferred, as ascertained in the manner prescribed" not assessed upon the shareholders but upon the company and paid by…
1Opinion of the Court
*17OPINION.
Smith:
The net income of a life insurance company upon wh,ich the income tax is imposed is determined in an entirely different manner under the Revenue Acts of 1921 and 1924 from the way in which it was determined in prior income-tax acts. When the bill (H. R. 8245) which later became the Revenue Act of 1921, was introduced in the Senate it was accompanied by a report of the Finance Committee in which it was stated:
Sections 242-246 provide a new plan for tbe taxation of life insurance companies, substantially similar to tbe plan embodied in tbe Revenue Act of 1918 as first adopted by…
2Cases cited11 opinions
- Pullman's Palace Car Co. v. PennsylvaniaSupreme Court of the United States · 1891
- Gloucester Ferry Co. v. PennsylvaniaSupreme Court of the United States · 1885
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
- New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
6 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Illinois Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Atlas Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Atlas Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
6 more not listed; retrieve them via the Exa API.