Carolina National Insurance v. South Carolina Tax Commission

Moss, Chief Justice:

Carolina National Insurance Company, during 1959-1963, and Carolina American Insurance Company, during the year 1963, the respondents herein, reinsured a number of fire insurance contracts issued by American Mutual Fire Insur*468anee Company. The South Carolina Tax Commission, the appellant herein, levied a two percent tax on the reinsurance premiums collected by the respondents, pursuant to Section 37-130.2 of the 1962 Code. The respondents paid the tax so levied under protest and separately instituted an action in 1967, pursuant to Section 65-2662, et seq. of the Code, to…