Rockford Life Insurance Co. v. Commissioner
292 U.S. 382 (1934)

Annotate this Case

U.S. Supreme Court

Rockford Life Insurance Co. v. Commissioner, 292 U.S. 382 (1934)

Rockford Life Insurance Co. v.

Commissioner of Internal Revenue

No. 722

Argued April 4, 1934

Decided May 21, 1934

292 U.S. 382

Syllabus

1. Under the Revenue Act of 1928, a life insurance company is not allowed to deduct from gross income the expense of a building owned and occupied in whole or in part by it unless there is included in the return of gross income the rental value of the space so occupied, not less than a sum which, in addition to any rents received from other tenants, shall provide a net income, after deducting taxes, depreciation, and other expenses at the rate of 40 per annum of the book value. Helvering v. Independent Life Ins. Co., ante, p. 292 U. S. 371, followed. P. 292 U. S. 383.

2. The deduction from gross income which a life insurance company may make under § 203(a)(7) of the Revenue Act of 1928, as a "reasonable" allowance for depreciation of furniture and fixture, is limited to such property as may fairly be allocated to its investment business, the income of which is taxed, as distinguished from its underwriting business, the income of which is not taxed. P. 292 U. S. 384.

67 F.2d 213 affirmed.

Certiorari, 291 U.S. 655, to review the reversal on appeal of a decision of the Board of Tax Appeals overruling a deficiency assessment against the Insurance Company and finding an overassessment.

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