Manhattan Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. A corporation engaged in the life insurance business is entitled to a deduction for exhaustion of furniture and fixtures used in both the underwriting and investment departments of its business. Lafayette Life Ins. Co.,26 B.T.A. 946, followed. 2. The petitioner, a life insurance company, in 1927 obtained the cancellation of a lease by the lessee and entered into a new lease on the same premises. The new lease was terminated in 1928 by court order.
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1. A corporation engaged in the life insurance business is entitled to a deduction for exhaustion of furniture and fixtures used in both the underwriting and investment departments of its business. Lafayette Life Ins. Co.,26 B.T.A. 946, followed. 2. The petitioner, a life insurance company, in 1927 obtained the cancellation of a lease by the lessee and entered into a new lease on the same premises. The new lease was terminated in 1928 by court order. Held, petitioner is entitled to deduct from its gross income in 1928 so much of the expenditure made to acquire the unexpired term of the old…
1Opinion of the Court
OPINION.
Arundell :
This proceeding involves the redetermination of a deficiency of $879.19 in income tax for 1928.
In its income tax return for 1928 the petitioner, a New York corporation engaged in the life insurance business, claimed a deduction for exhaustion on furniture and fixtures used in both the investment and underwriting departments of its business. In his audit of the return the respondent allowed the sum of $1,169.08 as a deduction for exhaustion on the portion of the assets used in the investment department, and disallowed the remainder on the ground that the statute made no…
2Cases cited4 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- American National Co. v. United StatesSupreme Court of the United States · 1927
- Miller v. CommissionerUnited States Board of Tax Appeals · 1928
- Lafayette Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by6 opinions
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Wells Fargo Bank & Union Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1947
- American Spring & Wire Specialty Co. v. CommissionerUnited States Tax Court · 1961
- Manhattan Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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