Manufacturers Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. In computing the net taxable income from sources within the United States of a foreign life insurance company the tax-free interest from obligations of the United States and tax-free dividends from domestic corporations are to be deducted from worldwide income, rather than from the income from sources within the United States only; and as so construed the statute is not unconstitutional. 2. Reserves held for payment of furture unaccrued and contingent liabilities under…
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1. In computing the net taxable income from sources within the United States of a foreign life insurance company the tax-free interest from obligations of the United States and tax-free dividends from domestic corporations are to be deducted from worldwide income, rather than from the income from sources within the United States only; and as so construed the statute is not unconstitutional. 2. Reserves held for payment of furture unaccrued and contingent liabilities under permanent total disability provisions of life insurance surance policies, where the insured was disabled at the date of…
1Opinion of the Court
THE MANUFACTURERS LIFE INSURANCE COMPANY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Manufacturers Life Ins. Co. v. Commissioner
Docket No. 90845.
United States Board of Tax Appeals
43 B.T.A. 867; 1941 BTA LEXIS 1435;
March 12, 1941, Promulgated
1. In computing the net taxable income from sources within the United States of a foreign life insurance company the tax-free interest from obligations of the United States and tax-free dividends from domestic corporations are to be deducted from worldwide income, rather than from the income from sources within the United States only; and…
2Cases cited36 opinions
- Ashwander v. Tennessee Valley AuthoritySupreme Court of the United States · 1936
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Steward MacHine Co. v. DavisSupreme Court of the United States · 1937
- Knowlton v. MooreSupreme Court of the United States · 1900
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