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C. P. A. COMPANY v. COMMISSIONER OF INTERNAL REVENUE

No. 9194.

134 F.2d 616 (1943)

C. P. A. COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Circuit Court of Appeals, Sixth Circuit.

February 17, 1943.

Attorney(s) appearing for the Case

John M. Hudson and Thomas F. Chawke, both of Detroit, Mich., for petitioner.

Samuel O. Clark, Jr., J. W. Wenchel, Sewall Key, Claude R. Marshall, and Arthur A. Armstrong, all of Washington, D. C., for respondent.

Before HAMILTON, MARTIN, and McALLISTER, Circuit Judges.

PER CURIAM.

On stipulation, it was agreed that if petitioner is a life insurance company according to the definition set forth in the provisions of Sec. 201(a) of the Revenue Acts of 1934 and 1936, 26 U.S.C.A. Int. Rev.Code, § 201(a), it is not subject to income tax for those years; otherwise, it is so liable. These statutory provisions define a life insurance company as one "engaged in the business of issuing life insurance and annuity contracts (including contracts...

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