MANUFACTURERS LIFE INSURANCE CO. v. COMMISSIONER

Docket No. 1368.

4 T.C. 811 (1945)

THE MANUFACTURERS LIFE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 26, 1945.


Attorney(s) appearing for the Case

John W. Townsend, Esq., for the petitioner.

Paul A. Sebastian, Esq., for the respondent.


The petitioner asks for a redetermination of a deficiency in income tax for the calendar year 1940 in the amount of $10,344.29. The questions in issue are:

(1) Whether the respondent erred in including in the gross income of the petitioner $124,446.56 representing accrued interest on mortgage loans realized through the acquisition of mortgaged property by foreclosure proceedings.

(2) Whether the petitioner is entitled to deduct from gross income $16,255.28...

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