Boston Ins. Co. v. United States

The plaintiff insurance company is a Massachusetts corporation engaged in writing fire and marine insurance. Among other States in which it transacts business is the State of New York, and in order to do so it must comply with the laws of New York relating to a foreign insurance company seeking to write insurance in that State. This the plaintiff did. It acceded to all the requirements exacted *611of it by the superintendent of insurance and did a large volume of business within that State.

The plaintiff company filed with the Commissioner of Internal Revenue its income-tax return for the year…