Manhattan Mut. Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
The petitioner, a newly organized mutual life insurance company, issued certain certificates for the purpose of creating a special fund "for the further advancement of the business of the Company" and to "maintain a Surplus Guaranty Fund" as provided for in the laws of the State of Kansas.
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The petitioner, a newly organized mutual life insurance company, issued certain certificates for the purpose of creating a special fund "for the further advancement of the business of the Company" and to "maintain a Surplus Guaranty Fund" as provided for in the laws of the State of Kansas. The certificates bore guaranteed interest of 6 percent, were redeemable at par after 10 years, out of surplus only, and the holders thereof were to receive an additional 2 1/2 percent of renewal premiums received by the company after a certain date for the period of 20 years, regardless of the retirement of…
1Opinion of the Court
OPINION.
Smith:
This proceeding involves a deficiency of $365.45 in petitioner’s income tax for 1932. Several of the issues raised in the petition have been abandoned, as set forth in paragraph 3 of the written stipulation filed herein. The remaining issues involve the question of the inclusion in petitioner’s gross income of interest accrued on real estate loans at the time the properties were acquired by the petitioner and the question of the deductibility of an amount paid out by the petitioner during the taxable year to the holders of its surplus guaranty fund certificates and claimed as…
2Cited by14 opinions
- Allan v. CommissionerUnited States Tax Court · 1986
- Commissioner of Internal Revenue v. Union Mutual Insurance Company of ProvidenceCourt of Appeals for the First Circuit · 1967
- Union Mut. Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Newhouse v. CommissionerUnited States Tax Court · 1973
- Commissioner v. VandeveerCourt of Appeals for the Sixth Circuit · 1940
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