London & Lancashire Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. In determining the proper ratio for apportioning unallocable expenses and taxes incurred by a British insurance company at its head office in England in connection with income from sources within and without the United States, where it did a fire and marine insurance besiness in 1930, tax-exempt interest and dividends from domestic corporations should not be included as a part of gross income from sources within the United States, but should be included in total gross…
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1. In determining the proper ratio for apportioning unallocable expenses and taxes incurred by a British insurance company at its head office in England in connection with income from sources within and without the United States, where it did a fire and marine insurance besiness in 1930, tax-exempt interest and dividends from domestic corporations should not be included as a part of gross income from sources within the United States, but should be included in total gross income from all sources. 2. Pursuant to provisions of the British income tax law, the petitioner paid to Great Britain in…
1Opinion of the Court
OPINION.
Seawell:
The Commissioner determined a deficiency of $5,123.91 for the calendar year 1930. The facts have been either stipulated or established by allegations in an amended petition which are admitted in the answer thereto.
The petitioner is a foreign insurance company, incorporated finder the laws of Great Britain and Ireland, with its head office in London, England. It transacts fire, marine, accident, life, and other classes of insurance throughout the world. During the year 1930, and for many years prior thereto and since, it carried on a fire and marine insurance business in the…
2Cases cited2 opinions
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- British-American Tobacco Co. v. HelveringSupreme Court of the United States · 1934
3Cited by7 opinions
- Commercial Union Assur. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1944
- Third Scottish American Trust Co. v. United StatesUnited States Court of Claims · 1941
- Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Gladstone Co. v. CommissionerUnited States Board of Tax Appeals · 1937
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