Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue

Third Circuit

Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue

199 F.2d 308

CourtCourt of Appeals for the Third Circuit

DecidedOctober 22, 1952

Docket10756

StatusPublished

This text of 199 F.2d 308 (Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue, 199 F.2d 308 (3d Cir. 1952).

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Opinion

PER CURIAM.

This petition for review of a decision by the Tax Court raises the question of the liability for income tax upon the reserve required of a title insurance company under the Pennsylvania law. We considered the question at length in Wayne Title and Trust. Co. v. Commissioner, 3 Cir., 1951, 195 F.2d 401, and we are not convinced that the taxpayer has shown us any reason for distinguishing that case from this.

' The decision of the Tax Court is affirmed.

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PER CURIAM.

This petition for review of a decision by the Tax Court raises the question of the liability for income tax upon the reserve required of a title insurance company under the Pennsylvania law. We considered the question at length in Wayne Title and Trust. Co. v. Commissioner, 3 Cir., 1951, 195 F.2d 401, and we are not convinced that the taxpayer has shown us any reason for distinguishing that case from this.

' The decision of the Tax Court is affirmed.

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199 F.2d 308, Counsel Stack Legal Research, https://law.counselstack.com/opinion/philadelphia-title-ins-co-v-commissioner-of-internal-revenue-ca3-1952.

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