Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined deficiencies in income tax for 1938, 1939, 1940 and 1941, of $102.12, $336.16, $844.67 and $2,096.61 and in excess profits tax of $98.73 for 1940. He disallowed an addition each year to a title policy loss reserve, holding that it represented earned premiums, and constituted merely a solvency reserve. The proceeding was presented on the following stipulation:
1. Petitioner is a corporation...
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