Hoosier Casualty Co. v. Commissioner
United States Board of Tax Appeals
1. Where a stock insurance company was organized to take over the business of a mutual insurance company and where only a fraction of one share of stock out of a total issue of $2,000 shares was acquired by the members of the mutual company, held, that these facts did not constitute a reorganization. 2. Where a stock insurance company on the day it began business took over the business of a mutual insurance company, which had been issuing combined policies of death, health…
Read the full summary
1. Where a stock insurance company was organized to take over the business of a mutual insurance company and where only a fraction of one share of stock out of a total issue of $2,000 shares was acquired by the members of the mutual company, held, that these facts did not constitute a reorganization. 2. Where a stock insurance company on the day it began business took over the business of a mutual insurance company, which had been issuing combined policies of death, health and accident insurance, and on the next day took over the business of an automobile insurance company, held, that the…
1Opinion of the Court
*1354OPINION.
Milliken:
The petitioner contends (1) that since the policyholders of the Mutual Company had the right to subscribe for stock in the Stock Company the latter was essentially the same as the former; (2) that from January 18,1921, to January 22,1921, the Stock Company was a life insurance company as that term is defined in section 242 of the Revenue Act of 1921; (3) that if the Stock Company was, when it took over the risks of the Mutual Company, an insurance *1355company other than a life or mutual insurance company and therefore falls under section 246 of the Revenue Act of 1921, then…
2Cases cited12 opinions
- Johannes v. Phenix Insurance Co. of BrooklynWisconsin Supreme Court · 1886
- United States Life Ins. v. SpinksCourt of Appeals of Kentucky · 1906
- People Ex Rel. Continental Ins. Co. v. . MillerNew York Court of Appeals · 1904
- Federal Life Insurance v. KerrIndiana Supreme Court · 1909
- Weil v. Federal Life InsuranceIllinois Supreme Court · 1914
7 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- American Title Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Hoosier Casualty Co. v. CommissionerUnited States Board of Tax Appeals · 1927