MUTUAL FIRE, MARINE & INLAND INSURANCE CO. v. COMMISSIONER

Docket No. 7459.

8 T.C. 1212 (1947)

THE MUTUAL FIRE, MARINE AND INLAND INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 19, 1947.


Attorney(s) appearing for the Case

J. C. Peacock, Esq., Paul F. Myers, Esq., and Morse Garwood, Esq., for the petitioner.

William D. Harris, Esq., for the respondent.


The respondent determined deficiencies in income tax for the calendar years ended December 31, 1940 and 1941, in the respective amounts of $28,152.17 and $10,754.50. The issues are whether the petitioner was exempt from Federal corporation income and excess profits taxes under section 101 (11) of the Internal Revenue Code as a mutual insurance company, and, if it was not so exempt, whether it was a mutual insurance company entitled under section 207 (c) (3) to deduct certain...

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