NORTH AMERICAN LIFE & CASUALTY CO. v. COMMISSIONER

Docket No. 4840-69.

63 T.C. 364 (1974)

NORTH AMERICAN LIFE AND CASUALTY COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 17, 1974.


Attorney(s) appearing for the Case

Edward G. Hearn and Michael J. Cuddy, for the petitioner.

Robert F. Cunningham, for the respondent.


WILES, Judge:

Respondent determined deficiencies in the income tax of petitioner for the years and in the amounts as follows:

    Year                        Deficiency

    1960 --------------------    $3,053.38
    1961 --------------------   121,168.00
    1963 --------------------    22,757.00

Some of the issues have been settled by the parties. The issues remaining for decision are:

(1) Whether petitioner...

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