Union Mut. Ins. Co. v. Commissioner
United States Tax Court
Mutual Insurance Company Other Than Life -- Interest on Guaranty Fund Certificates -- Sec. 822(c)(5). -- The guaranty fund certificates represented indebtedness within the meaning of section 822(c)(5) and the interest paid thereon was deductible by a mutual insurance company other than life.
1Opinion of the Court
The Commissioner determined deficiencies in income tax as follows:
Year Deficiency
1957 _$6,192.54
1958 _ 3,741.49
1959 _ 4,555.51
1960 _ 1,341.77
1961_ 5,617.21
1962 _ 10,257. 76
The issue for decision is whether the Commissioner erred in disallowing for each year a deduction of $35,000 as interest paid on indebtedness within section 822(c) (5).
FINDINGS OF FACT
The petitioner was incorporated under the laws of Rhode Island. It maintains its books and files its returns on a calendar year basis. Its returns for the years here involved were filed with the district director of internal revenue at…
2Cases cited8 opinions
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
- Holyoke Mut. Fire Ins. Co. v. CommissionerUnited States Tax Court · 1957
- Commonwealth v. Berkshire Life InsuranceMassachusetts Supreme Judicial Court · 1867
- Manhattan Mut. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Commissioner of Int. Rev. v. National Grange Mut. L. Co.Court of Appeals for the First Circuit · 1935
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Dunn v. CommissionerUnited States Tax Court · 1978
- Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Dunn v. CommissionerUnited States Tax Court · 1978
- Harbour Properties, Inc. v. CommissionerUnited States Tax Court · 1973
1 more not listed; retrieve them via the Exa API.