Samuel Nelson

“ There was no necessity, therefore, for any provision in the act of Congress as to insurance companies. Nor is any amendment called for. Insurance companies stand already upon the same footing as 'individual citizens.' Their taxable capital is taxed at the same rate as the shares of banks. ”

“ The statute of the State expressly forbids a higher rate of taxation.
This last proviso does not refer to corporations of any kind, but refers to private individuals-citizens of the State. The tax on bank shares is not to exceed the rate assessed upon other moneyed capital in the hands of such persons.
We submit that the words 'moneyed capital' refer only to such moneyed capital as is liable to assessment. They do not refer to bonds of the United States owned by individuals, for they are not moneyed capital liable to assessment. No assessment at all is to be made on such property. ”

“ Insurance companies in New York are subject to taxation of their capital, and the owners of stock in such companies are consequently exempt from taxation thereon. The stock so held by them, therefore, could not, under the laws of New York, be included in the valuation of their personal property in the assessment of taxes imposed by or under State authority. It is no answer, however, to say that the bank shares have not been assessed for valuation at a greater rate than insurance shares, because the latter are not assessed at all, and are not aubject under the State laws to taxation. ”