HELVERING V. INDEPENDENT LIFE INS CO.
292 U.S. 371 (1934)
NATURE OF THE CASE: This was a dispute over the rental value of a building. Herlvering
(D), commissioner, sought a writ of certiorari to review a decision that affirmed a decision
of the Board of Tax Appeals that P's deficiency assessments of income taxes against Life
insurance company (P) constituted a direct tax and were therefore invalid.
FACTS: Independent Life Ins. Co (P) owned an office building and used part of that
building for its own purposes. The IRS claimed that the fair market rental value of the
space that P used should be determined to be income. P claimed that such a tax could not be
levied as it would require apportionment of direct taxes. This appeal resulted.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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