James Clark McReynolds

“ Insurance Co. that the permitted deductions specified by section 12, Act 1916, do not necessarily include anything which may be denominated 'reserve fund' by state statute or officer. We there distinctly ruled that the 'reserve fund' of the federal act did not include something held by a fire and marine insurance company to cover accrued, but unsettled, claims for losses. We adhere to and reaffirm that doctrine. How far it must be modified, if at all, in respect of insurance companies which issue casualty, surety, or liability policies, or similar obligations, is not now before us. ”

“ The finding that the insurance department of Pennsylvania pursuant to statute, had at all times since and including 1909 required claimant to keep on hand, as a condition of doing business in the state, 'assets as reserves sufficient to cover outstanding losses,' without more, was not sufficient to justify the deduction of the reserve as one required by law to be maintained, within the meaning of the act of Congress. ”

“ The principal business of the company was employers' liability, accident, and workmen's compensation insurance, and it may be that considering certain state statutes, practice and general understanding, the term 'reserve fund' when used relative to the affairs of such a company should be given broader significance than when it refers only to fire and marine insurance. ”