AMERICAN EQUITABLE ASSUR. CO. OF NEW YORK v. HELVERING

No. 126.

68 F.2d 46 (1933)

AMERICAN EQUITABLE ASSUR. CO. OF NEW YORK v. HELVERING, Commissioner of Internal Revenue.

Circuit Court of Appeals, Second Circuit.

December 11, 1933.


Attorney(s) appearing for the Case

Le Roy B. Iserman, of New York City, for petitioner on review.

Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., for respondent on review.

Before L. HAND, SWAN, and CHASE, Circuit Judges.


CHASE, Circuit Judge.

On May 25, 1926, the petitioner purchased all the assets in this country of the Norwegian Atlas Insurance Company except "its rights to dividends or otherwise on its allowed claims against the Jefferson Insurance Company, the Liberty Marine Insurance Company and the North Atlantic Insurance Company, all in liquidation. * * *" It paid for them in part in cash and in part by assuming certain debts of the Norwegian Company.

The contract...

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