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AMERICAN NAT. INS. CO. v. COMMISSIONER OF INTERNAL REV.

No. 8105.

91 F.2d 705 (1937)

AMERICAN NAT. INS. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

July 16, 1937.

Attorney(s) appearing for the Case

Jas. W. Wayman, of Galveston, Tex., for petitioner.

Jno. W. Townsend, of Washington, D. C., on behalf of petitioner and as amicus curiæ.

Edward F. H. Horton, Sewall Key and Helen Carloss, Sp. Assts. to Atty. Gen., James W. Morris and Robert H. Jackson, Asst. Attys. Gen., and Herman Oliphant, Gen. Counsel, Dept. of Treasury, and Lloyd W. Creason, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before FOSTER, SIBLEY, and HUTCHESON, Circuit Judges.

FOSTER, Circuit Judge.

Petitioner is a life insurance company, incorporated under the laws of Texas. It owns a building in Galveston, part of which it occupies for the purpose of its business and the other part is rented to tenants. In making returns for income taxes for the years 1923, 1924, 1925, 1926, 1928, 1929, and 1930, it sought to take deductions for taxes and other expenses and depreciation on this building. The Commissioner ruled adversely on these claims...

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