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JEFFERSON STANDARD LIFE INSURANCE COMPANY v. COMMISSIONER OF INTERNAL REVENUE

No. 4018.

83 F.2d 1012 (1936)

JEFFERSON STANDARD LIFE INSURANCE COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Circuit Court of Appeals, Fourth Circuit.

June 11, 1936.

Attorney(s) appearing for the Case

Julius C. Smith, of Greensboro, N. C., for petitioner.

Helen R. Carloss, Sp. Asst. to Atty. Gen. (Robert H. Jackson, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on brief), for respondent.

John W. Townsend, of Washington, D. C., amicus curiæ.

Before PARKER, NORTHCOTT, and SOPER, Circuit Judges.

PER CURIAM.

On the authority of Helvering v. Independent Life Ins. Co., 292 U.S. 371, 54 S.Ct. 758, 78 L.Ed. 1311, we are of opinion that the decision of the Board of Tax Appeals in this case should be reversed. We are also of opinion that, as it is admitted by both sides and found by the Board that the book value of the home office building should have been $2,940,018.47 instead of $3,069,498.47, the deficiency properly assessable...

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