Helvering v. Midland Mutual Life Insurance

*220Mr. Justice Brandéis

delivered the opinion of the Court.

Since 1921, the Revenue Acts have made this provision for taxing the income of life insurance companies.1 The gross income is limited to that “received during the taxable year from interest, dividends, and rents.” Upon the net income, ascertained by making prescribed deductions, the tax under the Act here applicable is 12 per cent.2 The general provisions of the Revenue Acts concerning capital “gains and losses” and “bad debts” are not applicable to life insurance companies.3

In 1930, the Midland Mutual Life Insurance Company of Ohio…