Helvering v. Independent Life INS Co.

292 U.S. 371 (1934)

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Nature of the Case

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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.