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HELVERING v. INTER-MOUNTAIN LIFE INSURANCE CO.

No. 537.

294 U.S. 686 (1935)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. INTER-MOUNTAIN LIFE INSURANCE CO.

Supreme Court of United States.

Decided April 1, 1935.

Attorney(s) appearing for the Case

Assistant Attorney General Wideman, with whom Solicitor General Biggs and Messrs. James W. Morris, Norman D. Keller, and Edward H. Horton were on the brief, for petitioner.

Mr. A.R. Serven, with whom Mr. Stephen W. Downey was on the brief, for respondent.

MR. JUSTICE BUTLER delivered the opinion of the Court.

The question for decision is whether assets held by the company in 1922 against matured and unpaid coupons attached to 20-payment life coupon nonparticipating policies, constituted a reserve fund required by law within the meaning of § 245 (a) (2) of the Revenue Act of 1921.1

That section declares that net income means gross income...

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