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COLUMBIA TITLE INSURANCE CO. v. COMMISSIONER

Docket Nos. 2211, 2212.

3 T.C. 1099 (1944)

THE COLUMBIA TITLE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. THE REAL ESTATE TITLE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 17, 1944.

Attorney(s) appearing for the Case

Louis M. Denit, Esq., for the petitioners.

Philip A. Bayer, Esq., for the respondent.

The Commissioner determined deficiencies of $431.94 and $498.29 in income taxes for the fiscal year ended November 30, 1940, holding that petitioners were not entitled to file returns as insurance companies under section 204, Internal Revenue Code.

FINDINGS OF FACT.

The petitioners are corporations organized under the General Incorporation Law of the District of Columbia. The Real Estate Title Insurance Co. was incorporated...

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