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CINCINNATI UNDERWRITERS A. CO. v. COMMISSIONER OF INT. REV.

No. 6095.

63 F.2d 309 (1933)

CINCINNATI UNDERWRITERS AGENCY CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

As Modified on Denial of Rehearing March 17, 1933.

Attorney(s) appearing for the Case

A. C. Harvey, of Chicago, Ill. (Charles A. Kreps, of Chicago, Ill., on the brief), for petitioner.

J. H. McEvers of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and C. M. Charest, both of Washington, D. C., on the brief), for respondent.

Before MOORMAN, HICKENLOOPER, and SIMONS, Circuit Judges.

MOORMAN, Circuit Judges.

The question in this case is whether the petitioner, an Ohio corporation engaged in soliciting insurance on a commission basis, but not engaged in assuming insurance risks or issuing insurance policies, should have been permitted to file consolidated tax returns for the years 1926 and 1927 with another Ohio corporation, the Eureka Security Fire & Marine Insurance Company, which was engaged in issuing insurance policies and assuming insurance...

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