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PACIFIC INS. CO. v. UNITED STATES

Civ. A. No. 861.

90 F.Supp. 328 (1950)

PACIFIC INS. CO., Limited, v. UNITED STATES.

United States District Court D. Hawaii.

May 5, 1950.

Attorney(s) appearing for the Case

Smith, Wild, Beebe & Cades, Milton Cades, Honolulu, T. H., for plaintiff.

Theron Lamar Caudle, Assistant Attorney General, Homer R. Miller, Andrew D. Sharpe, Special Assistants to the Attorney General, Ray J. O'Brien, United States Attorney, District of Hawaii, Honolulu, T. H., for defendant.

McLAUGHLIN, District Judge.

1. The Facts

The facts in this case have been stipulated. The plaintiff taxpayer is an Hawaiian corporation, and is an insurance company "other than life or mutual," as defined in section 204 of the Internal Revenue Code, infra, 26 U.S.C.A. § 204.

The plaintiff has regularly and consistently determined its taxable net income under the provisions of section 204, its books...

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