Royal Highlanders v. Commissioner
United States Tax Court
1. The exemption granted a fraternal beneficiary society operating under the lodge system for the exclusive benefit of its members ceases when the society changes its form of organization and becomes a mutual legal reserve life insurance company, and income thereafter received is subject to taxation even though derived from contracts issued or assets held during the period it was entitled to exemption. 2. An insurance company, which had been in existence for several years as…
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1. The exemption granted a fraternal beneficiary society operating under the lodge system for the exclusive benefit of its members ceases when the society changes its form of organization and becomes a mutual legal reserve life insurance company, and income thereafter received is subject to taxation even though derived from contracts issued or assets held during the period it was entitled to exemption. 2. An insurance company, which had been in existence for several years as an exempt corporation, lost its exempt status on May 4, 1937, and filed a return of its income for the period May 4,…
1Opinion of the Court
OPINION.
Mellott, Judge:
The Commissioner made several adjustments to the net income shown by petitioner’s returns for the calendar years 1937 and 1938 and determined deficiencies in income tax in the respective amounts of $10,729.89 and $5,686.08. Petitioner concedes that some of the adjustments are proper and that there is a deficiency in tax for each year.
Most of the basic facts are not in dispute. Those hereinafter set out have been gleaned from admissions made in the pleadings, from admissions or concessions at the hearing, and from documents received in evidence. Three witnesses, called…
2Cases cited9 opinions
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
- Heiner v. Colonial Trust Co.Supreme Court of the United States · 1927
- Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
- Bankers' Trust Co. v. BowersCourt of Appeals for the Second Circuit · 1923
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
- General Aniline & Film Corp. v. CommissionerUnited States Tax Court · 1944
- Jacobs v. CommissionerUnited States Tax Court · 1946
- Polish Army Veterans Post 147 v. CommissionerUnited States Tax Court · 1955
8 more not listed; retrieve them via the Exa API.