Legal Opinion

North American Reassurance Co. v. Commissioner

United States Board of Tax Appeals

Decided August 14, 1934No. Docket Nos. 52674, 60678Published

1. DEDUCTIONS - DEPRECIATION. - Petitioner held not to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting department of its business. Rockford Life Ins.

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1. DEDUCTIONS - DEPRECIATION. - Petitioner held not to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting department of its business. Rockford Life Ins. Co. v. Commissioner,292 U.S. 382, followed. 2. Id. - RESERVES. - The valuation or "separate liability" required by section 85 of the insurance statute of the State of New Yorkheld not to be a reserve required by law within contemplation of section 245(a)(2) of the Revenue Act of 1926 and section 203(a)(2) of the Revenue Act of 1928 and consequently not includable by petitioner in the…

1Opinion of the Court

NORTH AMERICAN REASSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

North American Reassurance Co. v. Commissioner

Docket Nos. 52674, 60678.

United States Board of Tax Appeals

31 B.T.A. 92; 1934 BTA LEXIS 1165;

August 14, 1934, Promulgated

1. DEDUCTIONS - DEPRECIATION. - Petitioner held not to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting department of its business. Rockford Life Ins. Co. v. Commissioner,292 U.S. 382, followed.

2. Id. - RESERVES. - The valuation or "separate liability" required by section 85…

2Cases cited2 opinions

  1. Rockford Life Insurance v. CommissionerSupreme Court of the United States · 1934
  2. North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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