Meridian Mut. Ins. Co. v. Commissioner
United States Tax Court
Held: 1. In determining the tax on a mutual insurance company other than life or marine under section 821, the tax on net investment income computed under section 821(a) (1) is first to be compared with the alternative tax on capital gains computed under section 1201(a) and the lesser of these is next to be compared with the tax computed under section 821(a) (2) on gross investment income and net premiums, the greater of these being the tax imposed. 2. A mutual insurance…
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Held: 1. In determining the tax on a mutual insurance company other than life or marine under section 821, the tax on net investment income computed under section 821(a) (1) is first to be compared with the alternative tax on capital gains computed under section 1201(a) and the lesser of these is next to be compared with the tax computed under section 821(a) (2) on gross investment income and net premiums, the greater of these being the tax imposed. 2. A mutual insurance company other than life or marine which redeems U.S. savings bonds Series G or K before maturity is not entitled to a…
1Opinion of the Court
OPINION
BRUCE, Judge:
The respondent determined deficiencies in income tax for the calendar years 1958 and 1959 in the respective amounts of $11,059.94 and $7,136.35.
Two issues are presented: The first concerns the method of computing the petitioner’s tax as a mutual insurance company other than life or marine. The second is whether petitioner is entitled to a deduction for a payment required on redemption of U.S. savings bonds, Series G and K.
The facts are stipulated and the stipulation is adopted as our findings of fact.
Petitioner is a corporation organized under the laws of the State of…
2Cases cited7 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- McIlhenny v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1930
- Automobile Club of Michigan v. CommissionerUnited States Tax Court · 1953
- Milleg v. CommissionerUnited States Tax Court · 1952
2 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Krieger v. CommissionerUnited States Tax Court · 1975
- Millers Nat'l Ins. Co. v. CommissionerUnited States Tax Court · 1970
- Eades v. CommissionerUnited States Tax Court · 1982
- Baird v. CommissionerUnited States Tax Court · 1981
- ABOUELNOOR v. COMMISSIONERUnited States Tax Court · 2005
6 more not listed; retrieve them via the Exa API.