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HELVERING v. OREGON INS. CO.

No. 564.

311 U.S. 267 (1940)

61 S.Ct. 207

85 L.Ed. 180

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. OREGON MUTUAL LIFE INSURANCE CO.

Supreme Court of United States.

Decided December 9, 1940.

Attorney(s) appearing for the Case

Mr. Arnold Raum, with whom Solicitor General Biddle, Assistant Attorney General Clark, and Messrs. Sewall Key and Edward H. Horton were on the brief, for petitioner.

Mr. William Marshall Bullitt for respondent.

MR. JUSTICE BLACK delivered the opinion of the Court.

In computing its net taxable income for 1933 and 1934, respondent took a deduction of 3 3/4% of the reserves it had set aside with respect to its combined policies of life, health, and accident insurance. Section 203 (a) (2) of the 1932 and 1934 Revenue Acts permits a life insurance company to deduct from its gross income "An amount equal to [3 3/4%] of the mean of the...

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