Legal Opinion
Commercial Union Assur. Co. v. Commissioner
Court of Appeals for the Second Circuit
Decided August 24, 1944No. Nos. 216, 217PublishedCited by 8 opinions
1Opinion of the Court
CHASE, Circuit Judge.
The petitioner is a British insurance corporation which does business in various parts of the world including the United States, where it was engaged in business during 1938 and 1939 with its principal office in this country in the City of New York. It was taxable during 1938 on its income from sources within the United States as a foreign insurance company, other than life or mutual, in accordance with the provisions of § 204 of the Revenue Act of 1938, and during 1939 in accordance with the corresponding section of the InternaURevenue Code, 26 U.S.C.A. Int.Rev. Code, §…
2Cases cited5 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Royal Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Commercial Union Assurance Co. v. CommissionerUnited States Tax Court · 1943
- London & Lancashire Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1936
- Third Scottish American Trust Co. v. United StatesUnited States Court of Claims · 1941
3Cited by8 opinions
- Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Commercial Union Assur. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1945
- The Title Guarantee Company v. The United StatesUnited States Court of Claims · 1970
- Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
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