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HANOVER INS. CO. v. C. I. R.

No. 78-1407.

598 F.2d 1211 (1979)

HANOVER INSURANCE COMPANY, Successor in interest to Massachusetts Bonding and Insurance Company, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, First Circuit.

Decided May 8, 1979.

Attorney(s) appearing for the Case

Paul A. Teschner, Chicago, Ill., for petitioner-appellant.

Daniel F. Ross, Atty., Tax Div., Dept. of Justice, Washington, D. C., with whom M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews and Richard W. Perkins, Attys., Tax Div., Dept. of Justice, Washington, D. C., were on brief, for respondent-appellee.

Before COFFIN, Chief Judge, BOWNES, Circuit Judge, PETTINE, District Judge.

PETTINE, District Judge.

Appellant Hanover Insurance Company (Hanover) seeks this Court's review of a decision of the United States Tax Court upholding the Commissioner's determination of a deficiency in the income tax of Massachusetts Bonding and Insurance Company (MBI) for the taxable year 1960. Hanover is the successor in interest to MBI, which was merged into Hanover on June 30, 1961.

MBI filed federal income tax returns for its calendar years 1959 and...

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