Union Mut. Ins. Co. v. Commissioner
United States Tax Court
Mutual Insurance Company Other Than Life -- Interest on Guaranty Fund Certificates -- Sec. 822(c)(5). -- The guaranty fund certificates represented indebtedness within the meaning of section 822(c)(5) and the interest paid thereon was deductible by a mutual insurance company other than life.
1Opinion of the Court
Union Mutual Insurance Company of Providence, Petitioner, v. Commissioner of Internal Revenue, Respondent
Union Mut. Ins. Co. v. Commissioner
Docket Nos. 657-64, 658-64
United States Tax Court
46 T.C. 842; 1966 U.S. Tax Ct. LEXIS 35;
September 30, 1966, Filed
Decisions will be entered under Rule 50.
Mutual Insurance Company Other Than Life -- Interest on Guaranty Fund Certificates -- Sec. 822(c)(5). -- The guaranty fund certificates represented indebtedness within the meaning of section 822(c)(5) and the interest paid thereon was deductible by a mutual insurance company other than life.
Carl J.…
Also in this document: Dissent.
2Cases cited10 opinions
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
- Holyoke Mut. Fire Ins. Co. v. CommissionerUnited States Tax Court · 1957
- Commonwealth v. Berkshire Life InsuranceMassachusetts Supreme Judicial Court · 1867
- Manhattan Mut. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Commissioner of Int. Rev. v. National Grange Mut. L. Co.Court of Appeals for the First Circuit · 1935
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