COMMISSIONER OF INT. REV. v. NEW HAMPSHIRE FIRE INS. CO.

Nos. 4012, 4013.

146 F.2d 697 (1945)

COMMISSIONER OF INTERNAL REVENUE v. NEW HAMPSHIRE FIRE INS. CO. NEW HAMPSHIRE FIRE INS. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

January 17, 1945.


Attorney(s) appearing for the Case

Bernard Chertcoff, Sp. Asst. to Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., and J. P. Wenchel, Chief Counsel, and John W. Smith, Sp. Atty., Bureau of Internal Revenue, all of Washington, D.C., for Commissioner of Internal Revenue.

Robert Ash and W. T. Durant, both of Washington, D. C., for New Hampshire Fire Ins. Co.

Before MAHONEY and WOODBURY, Circuit Judges, and PETERS, District Judge.


WOODBURY, Circuit Judge.

These cross petitions for review of a decision of the Tax Court of the United States raise questions with respect to the income tax liability of the New Hampshire Fire Insurance Company for the calendar years 1936, 1937 and 1938. The facts are stated in detail in the opinion of the Tax Court. 2 T.C. 708. For the purposes of these petitions they can be summarized.

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