Legal Opinion

Franklin Title & Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided March 28, 1935No. Docket Nos. 51947, 60167, 67804, 67805Published

1. A corporation authorized to do business as a fire insurance company, which issued fire insurance policies but reinsured its risks, was subject to tax under section 204 of the Revenue Act of 1928 and was not entitled to join in a consolidated return with any other corporation subject to tax under section 13 of that act. Sec. 141(e). 2. Stockholders of two separate corporations assigned their stock to trustees and received participation certificates.

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1. A corporation authorized to do business as a fire insurance company, which issued fire insurance policies but reinsured its risks, was subject to tax under section 204 of the Revenue Act of 1928 and was not entitled to join in a consolidated return with any other corporation subject to tax under section 13 of that act. Sec. 141(e). 2. Stockholders of two separate corporations assigned their stock to trustees and received participation certificates. The trustees were to receive and disburse such dividends as were declared and paid by the two companies and, with certain important exceptions,…

1Opinion of the Court

FRANKLIN TITLE & TRUST COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

BEN FRANKLIN FIRE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Franklin Title & Trust Co. v. Commissioner

Docket Nos. 51947, 60167, 67804, 67805.

United States Board of Tax Appeals

32 B.T.A. 266; 1935 BTA LEXIS 969;

March 28, 1935, Promulgated

1. A corporation authorized to do business as a fire insurance company, which issued fire insurance policies but reinsured its risks, was subject to tax under section 204 of the Revenue Act of 1928 and was not entitled to join in a…

2Cases cited17 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Brown v. HelveringSupreme Court of the United States · 1934
  3. Hecht v. MalleySupreme Court of the United States · 1924
  4. United States v. MitchellSupreme Court of the United States · 1926
  5. American National Co. v. United StatesSupreme Court of the United States · 1927

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