Legal Opinion

General American Life Ins. Co. v. Commissioner

United States Tax Court

Decided March 16, 1956No. Docket No. 53957Published

Held, royalties from oil and gas leases received by petitioner life insurance company did not constitute "rents" within the meaning of section 201 (c) (1). Held, further, penalty payments received by petitioner from mortgagors who prepaid their mortgage indebtedness constituted "interest" within the meaning of section 201 (c) (1).

1Opinion of the Court

General American Life Insurance Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

General American Life Ins. Co. v. Commissioner

Docket No. 53957

United States Tax Court

25 T.C. 1265; 1956 U.S. Tax Ct. LEXIS 239; 5 Oil & Gas Rep. 867;

March 16, 1956, Filed

Decision will be entered under Rule 50.

Held, royalties from oil and gas leases received by petitioner life insurance company did not constitute "rents" within the meaning of section 201 (c) (1). Held, further, penalty payments received by petitioner from mortgagors who prepaid their mortgage indebtedness constituted "interest"…

2Cases cited6 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. General American Life Ins. Co. v. CommissionerUnited States Tax Court · 1956
  4. Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance CompanyCourt of Appeals for the Second Circuit · 1955
  5. Bond Auto Loan Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1946

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