Sun Mutual Insurance v. Mayor of New York , 1 Seld. Notes 94 ( 1853 )

Mutual insurance companies are liable to taxation on their capital stock, under the statute “concerning the assessment of taxes on incorporated companies.”

The amount of capital on which they may be taxed, may vary according to the increase or diminution of their accumulated premiums, invested to produce income, or held to provide for losses, such accumulated premiums constituting capital liable to taxation.

(See 4 N. Y. 442; S. C., 8 N. Y. 743.)