Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $1,135.83 in the petitioner's income tax liability for the year 1939.
The primary issue is whether the petitioner, during the year 1939, was a life insurance company within the provisions of section 201 of the Internal Revenue Code, or was a mutual insurance company, other than life, within the meaning of section 207 thereof.
If the petitioner is held to be a mutual...
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