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CITIZENS FUND MUTUAL FIRE INSURANCE CO. v. COMMISSIONER

Docket No. 51781.

28 T.C. 1017 (1957)

CITIZENS FUND MUTUAL FIRE INSURANCE COMPANY, A CORPORATION, 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 a deficiency in petitioner's income tax for the calendar year 1948 of $24,347.41. The primary issue to be decided is whether petitioner was a mutual insurance company within the meaning of section 207 of the Internal Revenue Code of 1939. An alternative issue raised by amended petition and to be decided only if it is found that petitioner was not such a mutual insurance company, is whether, under section 204...

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