LITTLETON, Judge.
The Commissioner of Internal Revenue refused to allow the additional reserves claimed by plaintiff on the ground that they were not reserves required by law within the meaning of section 245 (a) (2) of the Revenue Act of 1921 and article 681 of reg. 62. The pertinent provisions of the revenue act of 1921, 42 Stat. 227, 261, are as follows:
"Sec. 243. That in lieu of the taxes imposed by sections 230 and 1000 and by Title III, there shall...
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