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HELVERING v. MIDLAND INS. CO.,

No. 257.

300 U.S. 216 (1937)

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

Supreme Court of United States.

Decided February 15, 1937.

Attorney(s) appearing for the Case

Mr. David E. Hudson, with whom Solicitor General Reed, Assistant Attorney General Jackson, and Messrs. Sewall Key and Maurice J. Mahoney were on the brief, for petitioner.

Mr. Wm. Marshall Bullitt, with whom Mr. F.J. Wright was on the brief, for respondent.

MR. JUSTICE BRANDEIS delivered the opinion of the Court.

Since 1921, the Revenue Acts have made this provision for taxing the income of life insurance companies.1 The gross income is limited to that "received during the taxable year from interest, dividends, and rents." Upon the net income, ascertained by making prescribed deductions, the tax under the Act here applicable is 12 per cent.

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