COMMISSIONER OF INTERNAL REV. v. GENERAL REINS. CORP.

No. 193, Docket 21837.

190 F.2d 148 (1951)

COMMISSIONER OF INTERNAL REVENUE v. GENERAL REINSURANCE CORP.

United States Court of Appeals Second Circuit.

Decided June 20, 1951.


Attorney(s) appearing for the Case

Theron Lamar Caudle, Asst.Atty. Gen., Ellis N. Slack, Lee A. Jackson and Harry Marselli, Special Assts., to the Atty. Gen., for petitioner.

Cedric A. Major, New York City, and E. Clyde Algire, Washington, D. C. (Dudley, Algire, Jones & Ostmann, Washington, D. C. of counsel), for respondent.

Before SWAN, CHASE and FRANK, Circuit Judges.


CHASE, Circuit Judge.

The respondent is a stock casualty and surety company and as such is taxed upon its income pursuant to the provisions of § 204 of the Internal Revenue Code, 26 U.S.C.A. § 204. It is a New York corporation having its principal office in the City of New York and it filed its income tax returns with the Collector for the Second District of New York. In so doing it computed its net taxable income in strict accordance with what was reflected...

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