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PACIFIC EMPLOYERS INS. CO. v. COMMISSIONER OF INT. REV.

No. 8166.

89 F.2d 186 (1937)

PACIFIC EMPLOYERS INS. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

March 29, 1937.

Attorney(s) appearing for the Case

Joseph D. Peeler and F. Britton McConnell, both of Los Angeles, Cal. (Ward Loveless, of Washington, D. C., of counsel), for petitioner.

Robert H. Jackson, Asst. Atty. Gen., and Sewall Key, Edward H. Horton, and A. F. Prescott, Sp. Assts. to Atty. Gen., for respondent.

Bernhard Knollenberg, of New York City, for American Auto. Ins. Co., amicus curiæ.

Before WILBUR, MATHEWS, and HANEY, Circuit Judges.

HANEY, Circuit Judge.

To review a decision of the Board of Tax Appeals this petition is presented to us.

Petitioner, a California corporation, has been, and is operating an insurance business solely in California. Fourteen-fifteenths of the net premium income of petitioner for the year 1930 was from workmen's compensation insurance, and the balance was from automobile liability, collision and property damage insurance, principally, and a small volume from...

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