Legal Opinion

Northwestern Mut. Fire Asso. v. Commissioner

United States Tax Court

Decided March 30, 1949No. Docket No. 16147Published

The petitioner, a domestic mutual fire insurance company doing business in Canada, paid taxes in 1942 and 1943 to Canada, measured by the net premiums received in Canada, less premiums paid for reinsurance, in accordance with the provisions of the Canadian Special War Revenue Act of 1915, as amended.

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The petitioner, a domestic mutual fire insurance company doing business in Canada, paid taxes in 1942 and 1943 to Canada, measured by the net premiums received in Canada, less premiums paid for reinsurance, in accordance with the provisions of the Canadian Special War Revenue Act of 1915, as amended. Held, the taxes paid upon the net premiums were not taxes "in lieu of a tax upon income" as those terms are used in section 131 (h), I. R. C., and petitioner is not entitled to a credit for income taxes paid to a foreign government under section 131, I. R. C.

1Opinion of the Court

Northwestern Mutual Fire Association, Petitioner, v. Commissioner of Internal Revenue, Respondent

Northwestern Mut. Fire Asso. v. Commissioner

Docket No. 16147

United States Tax Court

12 T.C. 498; 1949 U.S. Tax Ct. LEXIS 235;

March 30, 1949, Promulgated

Decision will be entered for the respondent.

The petitioner, a domestic mutual fire insurance company doing business in Canada, paid taxes in 1942 and 1943 to Canada, measured by the net premiums received in Canada, less premiums paid for reinsurance, in accordance with the provisions of the Canadian Special War Revenue Act of 1915, as amended. Held,…

2Cases cited7 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. New York & Honduras Rosario Mining Co. v. CommissionerUnited States Tax Court · 1947
  3. Commissioner of Insurance v. Commonwealth Mutual Liability InsuranceMassachusetts Supreme Judicial Court · 1941
  4. State v. Minneapolis St. Louis Railroad Co.Supreme Court of Minnesota · 1939
  5. Vinup v. City of SeattleWashington Supreme Court · 1941

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