Legal Opinion

Holyoke Mut. Fire Ins. Co. v. Commissioner

United States Tax Court

Decided April 23, 1957No. Docket No. 51780Published

Petitioner was chartered in 1843 as a mutual fire insurance company under the laws of Massachusetts. Since 1873 it has had a guaranty fund of $ 100,000 divided into 1,000 shares. The shareholders are entitled to receive interest at 7 per cent per year, cumulatively, and to elect half the board of directors all of whom must be policyholders. Held, the petitioner is taxable under section 207, I. R. C. 1939, as a mutual insurance company.

1Opinion of the Court

Holyoke Mutual Fire Insurance Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Holyoke Mut. Fire Ins. Co. v. Commissioner

Docket No. 51780

United States Tax Court

28 T.C. 112; 1957 U.S. Tax Ct. LEXIS 210;

April 23, 1957, Filed

Decision will be entered for the petitioner.

Petitioner was chartered in 1843 as a mutual fire insurance company under the laws of Massachusetts. Since 1873 it has had a guaranty fund of $ 100,000 divided into 1,000 shares. The shareholders are entitled to receive interest at 7 per cent per year, cumulatively, and to elect half the board of directors all of…

2Cases cited19 opinions

  1. Norwegian Nitrogen Products Co. v. United StatesSupreme Court of the United States · 1933
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. Brewster v. GageSupreme Court of the United States · 1930
  4. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  5. Morrissey v. CommissionerSupreme Court of the United States · 1935

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