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MacLAUGHLIN v. PHILADELPHIA CONTRIBUTIONSHIP, ETC.

No. 5411.

73 F.2d 582 (1934)

MacLAUGHLIN v. PHILADELPHIA CONTRIBUTIONSHIP FOR INS. OF HOUSES FROM LOSS BY FIRE.

Circuit Court of Appeals, Third Circuit.

Rehearing Denied December 3, 1934.

Attorney(s) appearing for the Case

Frank J. Wideman, Asst. Atty. Gen., Sewall Key and Edward H. Horton, Sp. Assts. to Atty. Gen., and Charles D. McAvoy, U. S. Atty., and T. J. Curtin, Asst. U. S. Atty., both of Philadelphia, Pa., for appellant.

Frederick E. S. Morrison, Charles J. Biddle, and Drinker, Biddle & Reath, all of Philadelphia, Pa., for appellee.

Before WOOLLEY, DAVIS, and THOMPSON, Circuit Judges.

DAVIS, Circuit Judge.

The question in this case is whether or not the Philadelphia Contributionship, the plaintiff-appellee, is exempt from taxes on its income under section 231 (11) of the Revenue Act of 1926 (26 USCA § 982 (11), as a mutual fire insurance company, "the income of which is used or held for the purpose of paying losses or expenses."

The plaintiff is a mutual fire insurance company largely doing business in Philadelphia. Only the holders...

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