Equitable Life Assur. Soc’y v. Commissioner, 321 U.S. 560 (1944)
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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.
Equitable Life Assur. Soc’y v. Commissioner, 321 U.S. 560 (1944)
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Equitable Life Assurance Society v. Commissioner of Internal Revenue No. 492 Argued March 8, 9, 1944 Decided March 27, 1944 321 U.S. 560
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SECOND CIRCUIT
Syllabus
1. Upon review of decisions of the Tax Court, it is not the function of the reviewing court to draw inferences from facts or to supplement stipulated facts. P. 563.
2. A decision of the Tax Court on review may be modified or reversed only if it is "not in accordance with law." P. 563.
3. "Interest" usually denotes an amount which one has contracted to pay for the use of borrowed money. P. 564.
4. Upon the record, "excess interest dividends" paid by the life insurance company were not, as a matter of law, "interest" within the meaning of § 203(a)(8) of the Revenue Act of 1932, and the Tax Court’s disallowance of their deduction as "interest on indebtedness" may not be set aside. P. 564.
5. Provisions of the Revenue Acts for deductions from taxes are to be strictly construed. P. 564.
137 F.2d 623 affirmed.
Certiorari, 320 U.S. 733, to review the affirmance of a decision of the Tax Court, 44 B.T.A. 293, disallowing taxpayer’s deduction of excess interest dividends.
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Chicago: U.S. Supreme Court, "Syllabus," Equitable Life Assur. Soc’y v. Commissioner, 321 U.S. 560 (1944) in 321 U.S. 560 321 U.S. 561. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=CNCUMKZ9VRV4HWG.
MLA: U.S. Supreme Court. "Syllabus." Equitable Life Assur. Soc’y v. Commissioner, 321 U.S. 560 (1944), in 321 U.S. 560, page 321 U.S. 561. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=CNCUMKZ9VRV4HWG.
Harvard: U.S. Supreme Court, 'Syllabus' in Equitable Life Assur. Soc’y v. Commissioner, 321 U.S. 560 (1944). cited in 1944, 321 U.S. 560, pp.321 U.S. 561. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=CNCUMKZ9VRV4HWG.
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