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Helvering v. Inter-Mountain Life Insurance Co., 294 U.S. 686 (1935)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Helvering v. Inter-Mountain Life Insurance Co., 294 U.S. 686 (1935)
Helvering v. Inter-Mountain Life Insurance Co. No. 537 Argued March 5, 7, 1935 Decided April 1, 1935 294 U.S. 686
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE TENTH CIRCUIT
Syllabus
1. Assets reserved by an insurance company against matured unsurrendered and unpaid coupons attached to its twenty-payment life coupon nonparticipating policies held not "reserve funds required by law" within the meaning of § 245(a)(2) of the Revenue Act of 121, allowing deduction of a percentage of the mean of such reserve funds in computing the net income of life insurance companies. P. 690.
2. Reserves against such matured and unsurrendered coupon are not essentially insurance reserves, and the latter alone constitute the base on which the deduction allowed by § 245(a)(2) is to be computed. P. 690.
3. The rule that ambiguities in tax statutes are to be resolved in favor of the taxpayer has no application to provisions for deductions; they are allowable only when plainly authorized. P. 689.
71 F.2d 962 reversed.
Certiorari, 293 U.S. 553, to review a judgment affirming a decision of the Board of Tax Appeals redetermining a deficiency in the income tax of the insurance company.
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Chicago:
U.S. Supreme Court, "Syllabus," Helvering v. Inter-Mountain Life Insurance Co., 294 U.S. 686 (1935) in 294 U.S. 686 294 U.S. 687. Original Sources, accessed July 1, 2025, http://www.originalsources.com/Document.aspx?DocID=H51JCPRB86PD52R.
MLA:
U.S. Supreme Court. "Syllabus." Helvering v. Inter-Mountain Life Insurance Co., 294 U.S. 686 (1935), in 294 U.S. 686, page 294 U.S. 687. Original Sources. 1 Jul. 2025. http://www.originalsources.com/Document.aspx?DocID=H51JCPRB86PD52R.
Harvard:
U.S. Supreme Court, 'Syllabus' in Helvering v. Inter-Mountain Life Insurance Co., 294 U.S. 686 (1935). cited in 1935, 294 U.S. 686, pp.294 U.S. 687. Original Sources, retrieved 1 July 2025, from http://www.originalsources.com/Document.aspx?DocID=H51JCPRB86PD52R.
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