Newark evening star and Newark advertiser. [volume] (Newark, N.J.) 1909-1916, 1913-04-16
STATE TAX BOARD
DECIDES PRU CASE
Allows Deduction of S463,3l4.
Disnlisses Appeal from Other
Newark Assessment.
SECTION Is OF GENERAL
TAX ACT IS CONSTRUED
Company Construction Adopted
on Liability Under Levy of
Federal, State, Other Taxes
tFrom a stan oorrespOndent,I

TRENTON, April 16,-The State
Board of Equalization of Taxes in
an opinion today, disposes of the ap-
peal of the Prudential Insurance
Company of America from the as
.sessment for personal taxes for 1912,
levied in the city of Newark.
Two items were involved in the APP
peal which the Prudential company
claimed to be debts or liabilities and
which. therefore, should be deducted
from the valuation of its property
for the purpose of taxation.
The State board ordered a reduce
ton of 1853, 314.69 from an assessment
of s1.SS5, 09279, which was levied for
Federal State and other taxes"
The board found that the reduced
amount was levied against the de-
ferred dividend fund of the Pruden-
tial for the year 1911, and was, in
fact, rs contended by the Prudential
company a liability of the concern.
A second item in dispute was the
''unearned interest and rent paid in
advance" amounting to $3.50, 71l97.
The State board refused to reduce
MIS- diiOuIll Oll luC SIOuliu mat lDt
Prudential company. in 1911, made an
appeal from a similar assessment,
which the State board also turned
down. The board held in the pre-
vious case that so much Of the Item
as represented interest paid in adj
vance on loans to policyholders was
not such a liability as the statute
permits to be deducted from the tax
able valuation of the Prudential
property The State Board, in dis
posing of this item, said that after a
careful reconslderation of the evil
denee the board was lead to the same
conclusion as set forth in the prior
appeal.
The Boards Opinion.
The opinion in full follows:
This appeal involves two items
claimed by the appellant to be debts
or liabilities which 1t is entitled to
deduct from the valuation of it's
property for the purposes of taxation.
1.-THE first of these items for which
a deduction is claimed is: Federal,
State and other taxes, $1,SS5, 09279.' As
to this item the only dispute relates
to the sum of 1858, 314.69, levied as a
tax by the city of Newark against
the deferred dividend fund of the APP
pellant company for the year 1911.
THE second item in dispute is.
'Unearned interest and rent paid in
advance, $46O,7l1.97. The question as
to the right of the taxpayer to deduct
this item was involved in an appeal
of the present petitioner to this board
from its assessment for 1911, and in
that case we held that so much of the
item as represented interest paid in
advance on loans to policyholders was
not such a liability as the statute
permits to be deducted from the tax
able valuation of the company's prop
erty. A careful reconsideration of the
matter. after hearing the additional
evidence produced by the petitioner
and the able argument of counsel, has
led us to the same conclusions as
there set forth in the memorandum
filed in the prior appeal.
What Section IS Provides.
1.-THE first item is sought to be de-
Quoted from the assessable value of
The appellant companys property on
the ground that 1t represents a LA
hility Life insurance companies are
taxed under section Is of the general
tax act, which provides that such
corporations shall be assessed and
taxed for the full amount of their
property Exclusive of real estate To-
Gated in this State), deducting the
amount of their debts and liabilities,
and to ascertain the said amounts
a Statement of the property and debts
and liabilities of such association or
corporation as they existed on the
thirty-first day of December next pre-
ceding such statement. shall be an
nnally made TO the assessor in the
township, city or taxing district
where the principal office of the asso-