WESTERN CASUALTY & SURETY CO. v. COMMISSIONER

Docket No. 5971-72.

65 T.C. 897 (1976)

THE WESTERN CASUALTY AND SURETY COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 3, 1976.


Attorney(s) appearing for the Case

Reece A. Gardner and George E. Gibson, for the petitioner.

Edward G. Lavery, for the respondent.


FORRESTER, Judge:*

Respondent has determined deficiencies in petitioner's income tax for taxable years 1967, 1968, and 1969, and petitioner claims refunds for those years in the following amounts:

                                           Deficiency        Refund

        1967 ------------------------     $5,536,716.34     $290,138
        1968 ------------------------        465,213.26      118,976...

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