RESERVE LOAN LIFE INSURANCE COMPANY OF TEXAS v. COMMISSIONER

Docket No. 3676.

4 T.C. 732 (1945)

RESERVE LOAN LIFE INSURANCE COMPANY OF TEXAS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 8, 1945.


Attorney(s) appearing for the Case

George S. Atkinson, Esq., for the petitioner.

J. Marvin Kelley, Esq., for the respondent.


This case involves deficiencies in income tax for the taxable year ended December 31, 1940, in the amount of $34,818.34, and in excess profits tax for the same period in the amount of $21,923.20.

The first issue presented is whether petitioner's taxable year, within the language of section 203 (a) (2) of the Internal Revenue Code, began on March 23, 1940, or, on the other hand, on January 1, 1940. The date affects the amount of petitioner's deduction based upon its...

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