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PHILADELPHIA MANUFACTURERS MUTUAL INSURANCE COMPANY v. COMMISSIONER OF INTERNAL REVENUE

No. 13325.

284 F.2d 296 (1960)

PHILADELPHIA MANUFACTURERS MUTUAL INSURANCE COMPANY (formerly Philadelphia Manufacturers Mutual Fire Insurance Company), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided November 18, 1960.

Attorney(s) appearing for the Case

Harry L. Brown, Washington, D. C. (Alvord & Alvord, Washington, D. C., Ambrose B. Kelly, Providence, R. I., on the brief), for petitioner.

Melva M. Graney, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Helen A. Buckley, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before McLAUGHLIN, KALODNER and HASTIE, Circuit Judges.

PER CURIAM.

Petitioner is engaged in the mutual fire insurance business. It seeks to have its tax computed under Section 204 of the Internal Revenue Code of 1939, 26 U.S. C.A. § 204 (the counterpart of Section 831 of the 1954 Code, 26 U.S.C.A. § 831). The Tax Court upheld the Commissioner's decision that it should be taxed under Section 207 of the 1939 Code, 26 U.S. C.A. § 207 (the counterpart of Section 821 of the 1954 Code, 26 U.S.C.A. § 821...

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