North American Reassurance Co. v. Commissioner
United States Board of Tax Appeals
1. DEDUCTIONS - DEPRECIATION. - Petitioner held to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting as well as the investment department of its business. Lafayette Life Ins. Co.,26 B.T.A. 946; Missouri State Life Ins.
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1. DEDUCTIONS - DEPRECIATION. - Petitioner held to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting as well as the investment department of its business. Lafayette Life Ins. Co.,26 B.T.A. 946; Missouri State Life Ins. Co.,29 B.T.A. 401, followed. 2. Id. - RESERVES. - The valuation or "separate liability" required by section 85 of the insurance statute of the State of New York held not to be a reserve required by law within contemplation of section 245(a)(2) of the Revenue Act of 1926 and section 203(a)(2) of the Revenue Act of 1928…
1Opinion of the Court
*686OPINION.
Leech:
In reference to the first issue, petitioner is entitled to a reasonable allowance for depreciation of furniture and fixtures used in its business. This deduction is not limited to the furniture and fixtures used in the investment department of such business. Lafa*687yette Life Ins. Co., 26 B.T.A. 946; Missouri State Life Ins. Co., 29 B.T.A. 401. We hold that a reasonable allowance for depreciation is at the rate of 10 percent of the total cost, which rate was used by respondent in computing depreciation allowed upon furniture and fixtures in the investment department. The total cost…
2Cases cited11 opinions
- New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- United States v. Boston InsuranceSupreme Court of the United States · 1925
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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3Cited by2 opinions
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934