National Grange Mut. Liability Co. v. Commissioner
United States Board of Tax Appeals
1. Under section 103(11) of the Revenue Act of 1928, the exemption from taxation of "farmers' or other mutual * * * casualty * * * insurance companies", is not limited to farmers or similar organizations operating in a particular locality, but applies to all mutual casualty insurance companies whose income is used or held for the purpose of paying losses or expenses. 2. Whether a certain security is preferred stock or a debt depends upon the facts in each case. 3. The…
Read the full summary
1. Under section 103(11) of the Revenue Act of 1928, the exemption from taxation of "farmers' or other mutual * * * casualty * * * insurance companies", is not limited to farmers or similar organizations operating in a particular locality, but applies to all mutual casualty insurance companies whose income is used or held for the purpose of paying losses or expenses. 2. Whether a certain security is preferred stock or a debt depends upon the facts in each case. 3. The guaranty fund units issued by the petitioner were not preferred stock giving the holder an interest in the corporation, but an…
1Opinion of the Court
*668OPINION.
Murdock:
The first issue is whether or not the petitioner was exempt from tax under section 103(11) of the Eevenue Act of 1928.1 The respondent contends that farmers’ mutual insurance companies are a well-known class of small companies operating within a limited territory; the word “other”, under the rule of ejusdem generis, *669should be interpreted to include only such other companies as are similar in character to the farmers’ companies, thus excluding mutual companies which are not of a purely local character; the petitioner operates in a number of different states and is not of a…
2Cases cited6 opinions
- Penn Mutual Life Insurance v. LedererSupreme Court of the United States · 1920
- United States v. Standard Brewery, Inc.Supreme Court of the United States · 1920
- United States v. MescallSupreme Court of the United States · 1909
- Mid-Northern Oil Co. v. WalkerSupreme Court of the United States · 1925
- Danciger v. CooleySupreme Court of the United States · 1919
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Growers Credit Corp. v. CommissionerUnited States Tax Court · 1960
- Union Mut. Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Benjamin Franklin Life Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1942
- Eaton v. CommissionerUnited States Board of Tax Appeals · 1938
- Growers Credit Corp. v. CommissionerUnited States Tax Court · 1960
3 more not listed; retrieve them via the Exa API.