North American Reassurance Co. v. Commissioner
United States Board of Tax Appeals
1. DEDUCTIONS - DEPRECIATION. - Petitioner held not to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting department of its business. Rockford Life Ins.
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1. DEDUCTIONS - DEPRECIATION. - Petitioner held not to be entitled to a reasonable allowance for depreciation upon furniture and fixtures used in the underwriting department of its business. Rockford Life Ins. Co. v. Commissioner,292 U.S. 382, followed. 2. Id. - RESERVES. - The valuation or "separate liability" required by section 85 of the insurance statute of the State of New Yorkheld not to be a reserve required by law within contemplation of section 245(a)(2) of the Revenue Act of 1926 and section 203(a)(2) of the Revenue Act of 1928 and consequently not includable by petitioner in the…
1Opinion of the Court
OPINION.
Leech:
On January 5, 1934, the Board promulgated its opinion in these consolidated proceedings, reported at 29 B.T.A. 683, but the final decision has not been entered, due to the granting of a motion to withhold its entry pending the decision of the Supreme Court in the case of Rockford Life Iris. Co. v. Commissioner, 292 U.S. 382.
Respondent has now filed a motion for reconsideration and revision of the Board’s opinion with respect to its holding that petitioner was entitled to a deduction for depreciation upon furniture and fixtures used in the underwriting, as well as the investment…
2Cases cited3 opinions
- Rockford Life Insurance v. CommissionerSupreme Court of the United States · 1934
- Cascade Milling & Elevator Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by1 opinion
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934