John Hancock Mut. Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. A life insurance company which forecloses a mortgage upon which both principal and interest are due and unpaid and buys in the mortgaged property for the face value of the nortgage, has received thereby no gross income within the meaning of section 244(a) of the Revenue Act of 1921. 2. Commissioner's disallowance of a deduction of certain real estate taxes upon the property, paid by the petitioner after the foreclosure sale, approved.
1Opinion of the Court
*738OPINION.
Murdock :
The Revenue Act of 1921, in sections 242 to 247, inclusive, makes special provision for the taxation of insurance companies. The Commissioner does not contend that the provisions of these sections are not controlling in the determination of the tax liability of this petitioner. His deficiency notice shows that he applied them in making his own determination.
From an examination of these sections it is apparent that the gross income and allowable deductions applicable in the taxation of life insurance companies differ radically from the gross income and allowable deductions…
2Cases cited3 opinions
- Richardson v. City of BostonMassachusetts Supreme Judicial Court · 1889
- Rogers v. GookinMassachusetts Supreme Judicial Court · 1908
- O'Connell v. First Parish in MaldenMassachusetts Supreme Judicial Court · 1910
3Cited by22 opinions
- Merchants Bank Bldg. Co. v. HelveringCourt of Appeals for the Eighth Circuit · 1936
- Lifson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Commissioner of Internal Revenue v. Rust's EstateCourt of Appeals for the Fourth Circuit · 1940
- Hewitt v. CommissionerUnited States Board of Tax Appeals · 1934
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