PENN MUT. LIFE INS. CO. v. COMMISSIONER OF INTERNAL REV.

No. 6047.

92 F.2d 962 (1937)

PENN MUT. LIFE INS. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

October 28, 1937.


Attorney(s) appearing for the Case

Robert Dechert, of Philadelphia, Pa., for petitioner.

James W. Morris, Asst. Atty. Gen., and Sewall Key, Norman D. Keller, and Edward H. Horton, Sp. Assts. to Atty. Gen., for respondent.

Before THOMPSON and BIGGS, Circuit Judges, and DICKINSON, District Judge.


BIGGS, Circuit Judge.

This is an appeal from a decision of the Board of Tax Appeals. The petitioner is the Penn Mutual Life Insurance Company, a Pennsylvania corporation, engaged in carrying on the business of a mutual life insurance company, having no capital stock; and its policyholders constitute its members. The controversy here involved relates to alleged federal income tax deficiencies which were found by the Board of Tax Appeals to be in the amount of $38,884...

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