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AMERICAN TITLE CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 5482.

76 F.2d 332 (1935)

AMERICAN TITLE CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

March 12, 1935.

Attorney(s) appearing for the Case

Brown & Williams and Ira J. Williams, all of Philadelphia, Pa., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and Edward H. Horton, both of Washington, D. C., for respondent.

Before BUFFINGTON, WOOLLEY, and DAVIS, Circuit Judges.

PER CURIAM.

This case is here on the taxpayer's petition to review a decision of the United States Board of Tax Appeals sustaining and enlarging a deficiency tax assessed against it by the Commissioner of Internal Revenue. There are two questions:

1. Whether premiums paid a title insurance company for policies guaranteeing titles are earned when paid and constitute taxable income within the meaning of section 204 of the Revenue Act of 1928 (45 Stat. 791, 844...

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