Independent Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Section 245(b) denies to an insurance company any deduction for taxes, expenses, and depreciation, on account of real estate owned and occupied by it in whole or in part, unless the rental value of the space so occupied is included in gross income, and provides, "such rental value shall be not less than a sum which in addition to any rents received from other tenants shall provide a net income (after deducting taxes, depreciation, and all other expenses) at the rate of 4…
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1. Section 245(b) denies to an insurance company any deduction for taxes, expenses, and depreciation, on account of real estate owned and occupied by it in whole or in part, unless the rental value of the space so occupied is included in gross income, and provides, "such rental value shall be not less than a sum which in addition to any rents received from other tenants shall provide a net income (after deducting taxes, depreciation, and all other expenses) at the rate of 4 per centum per annum of the book value at the end of the taxable year of the real estate so owned or occupied." Held,…
1Opinion of the Court
INDEPENDENT LIFE INSURANCE CO. OF AMERICA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Independent Life Ins. Co. v. Commissioner
Docket No. 25295.
United States Board of Tax Appeals
17 B.T.A. 757; 1929 BTA LEXIS 2246;
October 4, 1929, Promulgated
1. Section 245(b) denies to an insurance company any deduction for taxes, expenses, and depreciation, on account of real estate owned and occupied by it in whole or in part, unless the rental value of the space so occupied is included in gross income, and provides, "such rental value shall be not less than a sum which in addition to any…
2Cases cited36 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- United States v. AndersonSupreme Court of the United States · 1926
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Pollock v. Farmers' Loan & Trust Co.Supreme Court of the United States · 1895
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