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COMMERCIAL UNION ASSUR. CO. v. COMMISSIONER OF INT. REV.

Nos. 216, 217.

144 F.2d 994 (1944)

COMMERCIAL UNION ASSUR. CO., Limited, v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

August 24, 1944.

Attorney(s) appearing for the Case

Edward S. Coons, Jr., of New York City, for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, J. Louis Monarch, and Bernard Chertcoff, Sp. Assts. to Atty. Gen., for respondent.

Before AUGUSTUS N. HAND, CHASE and FRANK, Circuit Judges.

CHASE, Circuit Judge.

The petitioner is a British insurance corporation which does business in various parts of the world including the United States, where it was engaged in business during 1938 and 1939 with its principal office in this country in the City of New York. It was taxable during 1938 on its income from sources within the United States as a foreign insurance company, other than life or mutual, in accordance with the provisions of § 204 of the Revenue...

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