This section contains the nature of the case and procedural background.

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.

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.