Legal Opinion

Great Nat. Life Ins. v. Campbell

District Court, N.D. Texas

Decided October 30, 1953No. Civ. A. No. 5211PublishedCited by 5 opinions

1Opinion of the Court

DAVIDSON, District Judge.

This is a suit to recover deficiencies in income taxes paid for the years 1949 and 195.0. Plaintiff, a life insurance company as defined in Section 201 of the Internal Revenue Code, Title 26, Internal Revenue Code, § 201, contends that bonus moneys Received and royalties paid from and under oil and gas leases covering minerals owned by it are not income subject to.tax. The Commissioner, taking the position that rents include such *58bonuses and royalties, has assessed deficiencies based thereon.

The facts are undisputed. The plaintiff is a life insurance company and is…

2Cases cited23 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Palmer v. BenderSupreme Court of the United States · 1932
  3. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  4. Anderson v. HelveringSupreme Court of the United States · 1940
  5. Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940

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3Cited by5 opinions

  1. Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance CompanyCourt of Appeals for the Second Circuit · 1955
  2. Pan-American Life Ins. Co. v. CommissionerUnited States Tax Court · 1955
  3. Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance CompanyCourt of Appeals for the Second Circuit · 1955
  4. Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance CompanyCourt of Appeals for the Second Circuit · 1955
  5. Pan-American Life Ins. Co. v. CommissionerUnited States Tax Court · 1955

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