Millers Nat'l Ins. Co. v. Commissioner
United States Tax Court
Petitioner is a mutual insurance company. In 1962 the income of petitioner from its underwriting business was not includable in gross income. That same year petitioner acquired tangible personal property for use in its underwriting activities. Held, for purposes of the investment credit such assets are not "section 38 property" within the meaning of sec. 48(a), I.R.C. 1954.
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined a deficiency of $3,818.59 in petitioner’s Federal income tax for 1962.
The sole issue before the Court is whether petitioner is entitled in 1962 to an investment credit on property used in its underwriting activities.
All of the facts were stipulated. The stipulation of facts, together with the exhibits attached thereto, is incorporated herein by this reference.
Petitioner is a corporation organized under the laws of the State of Illinois. Its principal place of business is in Chicago, Ill. Petitioner filed its Federal income tax return for calendar year…
2Cases cited4 opinions
- Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
- Louis Gorenc v. Salt River Project Agricultural Improvement and Power DistrictCourt of Appeals for the Ninth Circuit · 1989
- Rockford Life Insurance v. CommissionerSupreme Court of the United States · 1934
- Meridian Mut. Ins. Co. v. CommissionerUnited States Tax Court · 1965
3Cited by9 opinions
- Zuanich v. CommissionerUnited States Tax Court · 1981
- Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1973
- Alabama Displays, Inc. v. United StatesUnited States Court of Claims · 1974
- Oglebay Norton Co. v. United StatesUnited States Court of Claims · 1979
- Rickard v. CommissionerUnited States Tax Court · 1987
4 more not listed; retrieve them via the Exa API.