The Commissioner determined deficiencies in income tax for 1939 and 1940 in the respective amounts of $1,087.59 and $734.53. He held that no part of petitioner's reserve funds was held for the fulfillment of life insurance contracts within the meaning of section 201, Internal Revenue Code, and that petitioner was subject to tax under section 207 of the code. In computing petitioner's tax liability under section 207 he held that additions to petitioner's "mortuary reserve...
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