National Life Ins. Co. v. United States

LITTLETON, Judge.

The first question relates to the right of plaintiff, an insurance company, and the National Life Building Company, an ordinary corporation, to file consolidated returns for each of the years 1923 to 1926, inclusive, and have the tax for such years computed upon such consolidated net income. We think the commissioner correctly held that a life insurance company, either life or other than life or mutual, was not entitled under the Revenue Act of 1921 (42 Stat. 227, 240) and subsequent acts to file consolidated returns with an ordinary corporation taxable under the provisions…