PHILADELPHIA MANUFACTURERS MUTUAL INSURANCE CO. v. COMMISSIONER

Docket No. 66243.

33 T.C. 490 (1959)

PHILADELPHIA MANUFACTURERS MUTUAL INSURANCE COMPANY (FORMERLY PHILADELPHIA MANUFACTURERS MUTUAL FIRE INSURANCE COMPANY), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 10, 1959.


Attorney(s) appearing for the Case

Harry L. Brown, Esq., and Ambrose B. Kelly, Esq., for the petitioner.

William J. Hagan, Esq., for the respondent.


MULRONEY, Judge:

The respondent determined deficiencies in income tax of petitioner for the years 1952 and 1954 in the amounts of $12,985.01 and $43,410.35, respectively.

The sole question is whether petitioner, a mutual fire insurance company, is entitled to file its return and be taxed according to section 204, I.R.C. 1939, and section 831, I.R.C. 1954.

FINDINGS OF FACT.

Petitioner is engaged in carrying on a mutual fire insurance...

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