Memorandum Findings of Fact and Opinion
The respondent determined for the calendar year 1942 a deficiency in excess profits tax in the amount of $433,520.38 and an overassessment of income tax of $190,057.89. The petitioner, a casualty insurance company subject to tax under section 204 of the Internal Revenue Code, alleges that the respondent erred (1) in determining petitioner's deduction for losses incurred as of December 31, 1942, by using its own estimates of...
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