Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance Company

BORAH, Circuit Judge.

This case presents the question whether royalties are “rents” within the definition of the gross income of life insurance companies as set forth in Section 201(c) (1) of the Internal Revenue Code.1

The appellee here, the Great National Life Insurance Company, was during the period hereinafter mentioned, a life insurance company as defined in Section 201(b) of the Internal Revenue Code. In the conduct of its investment business and on some undisclosed date prior to the year 1949, appellee acquired vendor’s lien notes secured by land in Scurry County, Texas, and…