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PENNSYLVANIA CO., ETC. v. COMMISSIONER OF INTERNAL REV.

No. 5535.

75 F.2d 719 (1935)

PENNSYLVANIA CO. FOR INSURANCES ON LIVES AND GRANTING ANNUITIES v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

February 5, 1935.

Attorney(s) appearing for the Case

Walter Biddle Saul, of Philadelphia, Pa., for petitioner.

Warren F. Wattles, of Washington, D. C., Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., for respondent.

Before BUFFINGTON and WOOLLEY, Circuit Judges.

WOOLLEY, Circuit Judge.

Long prior to 1929, the Bank of North America and Trust Company, hereinafter called the Bank, and The Pennsylvania Company for Insurances on Lives and Granting Annuities, hereinafter called the old Pennsylvania Company, were separately engaged in a general banking, trust and safe-deposit business in Philadelphia. Both were Pennsylvania corporations. On April 25, 1929 the old Pennsylvania Company and the Bank entered into an "Agreement of Consolidation...

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