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HELVERING v. IND. LIFE INS. CO.

No. 689.

292 U.S. 371 (1934)

54 S.Ct. 758

78 L.Ed. 1311

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. INDEPENDENT LIFE INSURANCE CO.

Supreme Court of United States.

Decided May 21, 1934.

Attorney(s) appearing for the Case

Solicitor General Biggs, with whom Assistant Attorney General Wideman and Messrs. Sewall Key, J. Louis Monarch, and H. Brian Holland were on the brief, for petitioner.

Mr. Wm. Marshall Bullitt, with whom Mr. James A. Newman was on the brief, for respondent.

MR. JUSTICE BUTLER delivered the opinion of the Court.

This case involves the validity of deficiency assessments of income taxes made by the Commissioner against the life insurance company for 1923 and 1924. The 1921 Revenue Act (42 Stat. 261), § 244 (a) defines gross income of such companies as that received from interest, dividends and rents. Premiums and capital gains are...

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