Legal Opinion

Union Cent. Life Ins. Co. v. Commissioner

United States Tax Court

Decided March 11, 1985No. Docket No. 2094-78Published

The Court of Appeals held that in order to deduct general expenses from gross investment income under sec. 804(c)(1), I.R.C. 1954, they must be directly related to the production of investment income. Held, petitioner may not deduct any portion of the Ohio Franchise Tax because such tax was not directly related to the production of investment income.

1Opinion of the Court

The Union Central Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Union Cent. Life Ins. Co. v. Commissioner

Docket No. 2094-78

United States Tax Court

84 T.C. 361; 1985 U.S. Tax Ct. LEXIS 112; 84 T.C. No. 26;

March 11, 1985. March 11, 1985, Filed

Decision will be entered for the respondent.

The Court of Appeals held that in order to deduct general expenses from gross investment income under sec. 804(c)(1), I.R.C. 1954, they must be directly related to the production of investment income. Held, petitioner may not deduct any portion of the Ohio Franchise Tax because…

2Cases cited5 opinions

  1. Liberty Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-Appellee. Liberty Life Insurance Company, Plaintiff-Appellant-Cross-Appellee v. United States of America, Defendant-Appellee-Cross-AppellantCourt of Appeals for the Fourth Circuit · 1979
  2. Commissioner v. Volunteer State Life Ins.Court of Appeals for the Sixth Circuit · 1940
  3. The Union Central Life Insurance Company, Cross-Appellant v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Sixth Circuit · 1983
  4. Union Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1981
  5. Union Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1985

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