Legal Opinion
Commissioner v. National Reserve Ins.
Court of Appeals for the Ninth Circuit
Decided April 3, 1947No. 11417PublishedCited by 2 opinions
1Opinion of the Court
DENMAN, Circuit Judge.
The Commissioner seeks review of a decision of the Tax Court holding that the appellee, an Arizona corporation issuing policies of insurance on the assessment plan, hereinafter called the Company, was a life insurance company within the definition of Section 201(a) of the Internal Revenue Code, 26 U.S.C.A.Int.Rev.Code, § 201, and hence not liable for income tax deficiencies found by the Commissioner for the tax years 1939 and 1940 to be due on its income from assessment receipts for those years.
The Commissioner found that the Company was a mutual insurance company…
2Cases cited11 opinions
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
- Commissioner of Internal Rev. v. Monarch Life Ins. Co.Court of Appeals for the First Circuit · 1940
- New York Life Insurance v. BowersSupreme Court of the United States · 1931
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3Cited by2 opinions
- First National Benefit Society, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1950
- Idaho Mutual Benefit Ass'n v. United StatesDistrict Court, D. Idaho · 1966