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COMMISSIONER OF INT. REV. v. NATIONAL GRANGE MUT. L. CO.

No. 3049.

80 F.2d 316 (1935)

COMMISSIONER OF INTERNAL REVENUE v. NATIONAL GRANGE MUT. LIABILITY CO.

Circuit Court of Appeals, First Circuit.

November 27, 1935.

Attorney(s) appearing for the Case

Berryman Green, Sp. Asst. to Atty. Gen. (Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

H. C. Kilpatrick, of Washington, D. C., for respondent.

Before MORTON, Circuit Judge, and MORRIS and McLELLAN, District Judges.

MORTON, Circuit Judge.

The respondent claims to be a mutual casualty company and as such exempt from taxation. The Commissioner held that it was not exempt and assessed against it for the tax year 1931 income taxes in the sum of $3,186. On an appeal by the taxpayer the Board of Tax Appeals overruled the Commissioner and held that the company was exempt. The Commissioner has appealed. The statute involved is the Revenue Act of 1928, the exemption claimed resting on...

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