National City Bank v. Wilkins

{¶ 1} The issue presented to us in this case concerns whether life-insurance policies owned by National City Bank appreciated when the insurance carriers declared a dividend or made an interest payment that National City chose to take in the form of additions to the cash surrender value of its policies. Pursuant to R.C. 5733.05(A)(4) as it existed during the years in question, “appreciation” is excluded from a financial institution’s taxable net worth for Ohio franchise-tax purposes. The bank contends that the interest and dividend payments it received as additions to the cash surrender value…