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LINCOLN MORTGAGE & T. GUAR. CO. v. COMMISSIONER INT. REV.

No. 5685.

79 F.2d 585 (1935)

LINCOLN MORTGAGE & TITLE GUARANTY CO. et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

September 24, 1935.

Attorney(s) appearing for the Case

Merritt Lane and Bilder, Bilder & Kaufman, all of Newark, N. J. (Merritt Lane and Samuel Kaufman, both of Newark, N. J., and Louis Spiegler, of Washington, D. C., of counsel; Morris M. Schnitzer, of Newark, N. J., on the brief), for petitioners.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and Morton K. Rothschild, Sp. Assts. to Atty. Gen., for respondent.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

DAVIS, Circuit Judge.

This appeal involves the liability of the taxpayer, the Lincoln Mortgage & Title Guaranty Company, for income taxes for the years 1926 and 1927.

The taxpayer was incorporated under the insurance laws of the state of New Jersey and was operated under the direction and supervision of the department of banking and insurance of that state.

The taxpayer was principally engaged in the business...

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