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PHILADELPHIA MANUFACTURERS MUT. FIRE INS. CO. v. COMMISSIONER

Docket No. 20786.

10 T.C.M. 999 (1951)

Philadelphia Manufacturers Mutual Fire Insurance Company v. Commissioner.

United States Tax Court.

Entered October 18, 1951.

Attorney(s) appearing for the Case

James J. Cloran, Esq., for the petitioner. John A. Newton, Esq., for the respondent.

Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax of $1,032.14 and $1,215.24 for 1945 and 1946. The petitioner assigns as error the action of the Commissioner in denying credits under section 131 for Canadian taxes imposed in each year on net premiums received by the petitioner in Canada.

The facts have been stipulated and do not differ in principle from those in the case of Northwestern Mutual Fire Association...

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