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PROPERTY OWNERS MUTUAL INSURANCE COMPANY v. COMMISSIONER

Docket No. 51662.

28 T.C. 1007 (1957)

PROPERTY OWNERS MUTUAL INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 23, 1957.

Attorney(s) appearing for the Case

Charles R. Johnston, Esq., and Nicholas S. Kiefer, Esq., for the petitioner.

George E. Van Roekel, Esq., for the respondent.

Respondent determined deficiencies in petitioner's income tax for the calendar years 1946, 1948, and 1949 of $17,829.41, $27,455.25, and $9,807.51, respectively. By amended answer, respondent alleged that the correct deficiencies were:

Year                                 Deficiency

1946 -----------------------------   $24,188.45
1948 -----------------------------    42,543.50
1949 -----------------------------    35,625.41

The primary...

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