Massachusetts Mut. Life Ins. Co. v. United States, 288 U.S. 269 (1933)
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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.
Massachusetts Mut. Life Ins. Co. v. United States, 288 U.S. 269 (1933)
Massachusetts Mutual Life Insurance Co. v. United States No. 322 Argued January 16, 17, 1933 Decided February 6, 1933 288 U.S. 269
CERTIORARI TO THE COURT OF CLAIMS
Syllabus
1. Reenactment of a provision of a revenue act held a legislative adoption of the construction that had been placed upon it in administration by the Treasury Department. P. 273.
2. Section 245(8) of the Revenue Act of 1926, applicable to Life Insurance Companies (which make their returns only on the cash basis) permits deduction from gross income of "[a]ll interest paid or accrued within the taxable year" on a company’s indebtedness, with a certain exception. Held that interest accrued on dividends held for policyholders, but unpaid, is not deductible. Pp. 271, 275.
3. The general rule against accounting for and reporting income partly on the accrual and partly on the cash basis should apply to insurance companies; being required to treat interest received on the cash basis, they ought not to have the privilege of treating on the other basis the interest that they owe. P. 273.
75 Ct.Cls. 117, 59 F.2d 116, affirmed.
Certiorari, 287 U.S. 591, to review a judgment rejecting a claim to recover money paid as income taxes.
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Chicago: U.S. Supreme Court, "Syllabus," Massachusetts Mut. Life Ins. Co. v. United States, 288 U.S. 269 (1933) in 288 U.S. 269 Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=993F2IS4QKFC9Y1.
MLA: U.S. Supreme Court. "Syllabus." Massachusetts Mut. Life Ins. Co. v. United States, 288 U.S. 269 (1933), in 288 U.S. 269, Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=993F2IS4QKFC9Y1.
Harvard: U.S. Supreme Court, 'Syllabus' in Massachusetts Mut. Life Ins. Co. v. United States, 288 U.S. 269 (1933). cited in 1933, 288 U.S. 269. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=993F2IS4QKFC9Y1.
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