Helvering v. Independent Life Insurance

This case involves the validity of deficiency assessments of income taxes made by the Commissioner against the life insurance company for 1923 and 1924. The 1921 Revenue Act (42 Stat. 261), § 244 (a) defines gross in come of such companies as that received from interest, dividends and rents. Premiums and capital gains are excluded. Section 245 (a) directs that net income be ascertained by making specified deductions from gross income. These include four per cent, of the company’s reserve, “(6) Taxes and other expenses paid during the taxable year exclusively upon or with respect to the real…