COMMISSIONER OF INTERNAL REV. v. UNITED STATES GUARANTEE CO.

No. 195, Docket 21598.

190 F.2d 152 (1951)

COMMISSIONER OF INTERNAL REVENUE v. UNITED STATES GUARANTEE CO.

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.

John S. Breckinridge, New York City, for respondent.

Before SWAN, CHASE and FRANK, Circuit Judges.


CHASE, Circuit Judge.

The issues now before us are, as the parties agree, the same in principle as those considered in Commissioner of Internal Revenue v. General Reinsurance Corporation, 2 Cir., 190 F.2d 148, the opinion in which is handed down herewith. They are, whether in computing the net taxable income of the respondent for 1942 the so-called "Convention Form" should be followed precisely in computing the amount deductible from...

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