Opinion

Penn Mut. Indem. Co. v. Commissioner

32 T.C. 653
1959 U.S. Tax Ct. LEXIS 146

Court: United States Tax Court
Filed: Jun 15, 1959
Status: Published
Author: Turner
On the bench: Raum,Opper,Tietjens,Atkins,Tietjens,Fisher,Atkins,Withey,Train,Forrester
Cited by: 36 cases

The opinion

Turner, J., concurring: It is my opinion that the tax imposed by section 207 (a) (2) is a tax on income, and consequently any apportionment requirement is obviated by the 16th amendment. If I am wrong in that view, and in the disposition of the case it is necessary to consider the question of constitutionality apart from the 16th amendment, I concur in what is said in the majority opinion.

Harron, Teetjens, Fisher, and Atkins, //., agree with this concurring opinion.

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