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CUESTA TITLE GUARANTY CO. v. COMMISSIONER

Docket No. 7993-75.

71 T.C. 278 (1978)

CUESTA TITLE GUARANTY COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 22, 1978.

Attorney(s) appearing for the Case

Richard B. Dodge, for the petitioner.

Alan R. Herson, for the respondent.

WILBUR, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:


Year                        Deficiency

1971 .....................    $4,939
1972 .....................     9,035

The sole issue for decision is whether Cuesta Title Guaranty Co. (hereinafter petitioner) qualifies as an "insurance company" within the meaning of section 831.

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