Union Cent. Life Ins. Co. v. Commissioner
United States Tax Court
Held, a portion of the Ohio franchise tax paid by petitioner is properly deductible as an investment expense under sec. 804(c)(1), I.R.C. 1954. Held, further, unimproved land surrounding petitioner's home office building is includable in "assets" under sec. 805(b)(4), I.R.C. 1954.
1Opinion of the Court
Wiles, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Year Deficiency
1972 .$36,866.80
1973 . 65,075.56
1974 . 90,410.52
Several issues having been resolved by concessions1 prior to trial, the only issues remaining for decision are:(1) Whether any portion of the Ohio franchise tax paid by petitioner is deductible as an investment expense under section 804(c).2(2) Whether a portion of the unimproved land surrounding pétitioner’s home office building must be included in its "assets” under section 805(b)(4).
FINDINGS OF FACT
Some of the facts have been…
2Cases cited16 opinions
- General Motors Acceptance Corporation v. E. Mullins Whisnant, Trustee in Bankruptcy of John Chesley Fanjoy, Jr., BankruptCourt of Appeals for the Fifth Circuit · 1968
- United States v. Atlas Life Insurance Co.Supreme Court of the United States · 1965
- Jefferson Standard Life Insurance Company v. United States of America, (Two Cases). Jefferson Standard Life Insurance Company v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1969
- Rockford Life Insurance v. CommissionerSupreme Court of the United States · 1934
- Bayou Verret Land Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1971
11 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- Northwestern Mutual Life Insurance v. United StatesUnited States Court of Claims · 1985
- Union Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1985
- Phoenix Mut. Life Ins. Co. v. CommissionerUnited States Tax Court · 1991
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
4 more not listed; retrieve them via the Exa API.