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CITY TITLE INSURANCE COMPANY v. COMMISSIONER

Docket No. 49775.

14 T.C.M. 939 (1955)

T.C. Memo. 1955-233

City Title Insurance Company v. Commissioner.

United States Tax Court.

Filed August 19, 1955.

Attorney(s) appearing for the Case

Henry Halpern, Esq., 26 Court Street, Brooklyn, N. Y., for the petitioner. Ellyne E. Strickland, Esq., for the respondent.

Memorandum Opinion

RICE, Judge:

This proceeding involves deficiencies in income and excess profits taxes in the respective amounts of $7,256.69 and $491.70 determined by the respondent for the year 1945.

The only issue is whether a reserve for reinsurance in the amount of $27,701.25 against premiums received from June 1, 1938 to May 31, 1945, was properly deductible by petitioner as unearned premiums, within...

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