EDWARDS v. COMMISSIONER OF INTERNAL REVENUE

No. 16042.

242 F.2d 142 (1957)

Louise H. EDWARDS et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

March 14, 1957.


Attorney(s) appearing for the Case

George W. Ericksen, Chester H. Ferguson, Tampa, Fla., Macfarlane, Ferguson, Allison & Kelly, Tampa, Fla., of counsel, for petitioners.

Davis W. Morton, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, John Potts Barnes, Chief Counsel, Internal Revenue Service, Rollin H. Transue, Sp. Atty., Internal Revenue Service, Harry Baum, Atty., Dept. of Justice, Washington, D. C., for respondent.

Before RIVES, TUTTLE and JONES, Circuit Judges.


TUTTLE, Circuit Judge.

This is a petition for review of six related decisions of the Tax Court in which the only issue here is whether petitioners' transferor's right to a pro rata share of "unabsorbed premiums" of a mutual insurance company accrued to the transferors during its final, shortened fiscal year before its dissolution, or at some later date.

The pertinent facts are as follows:

On September 19, 1944, the Growers Mutual Insurance Company...

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