Holyoke Mut. Fire Ins. Co. v. Commissioner
United States Tax Court
Petitioner was chartered in 1843 as a mutual fire insurance company under the laws of Massachusetts. Since 1873 it has had a guaranty fund of $ 100,000 divided into 1,000 shares. The shareholders are entitled to receive interest at 7 per cent per year, cumulatively, and to elect half the board of directors all of whom must be policyholders. Held, the petitioner is taxable under section 207, I. R. C. 1939, as a mutual insurance company.
1Opinion of the Court
Tietjens, Judge:
The respondent determined a deficiency in income tax for the calendar year 1950 in the amount of $4,695.28. The sole issue is whether the petitioner was during that year an insurance company other than mutual, and taxable under section 204, Internal Revenue Code of 1939, or a mutual insurance company other than life or marine, and taxable under section 207 of such Code. Some facts are stipulated.
FINDINGS OF FACT.
The facts stipulated are so found and the exhibits to the stipulation are incorporated herein by this reference.
The petitioner is operating under the laws of…
2Cases cited17 opinions
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3Cited by22 opinions
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