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

Third Circuit

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

199 F.2d 308

Court of Appeals for the Third Circuit·Decided October 22, 1952·No. 10756·Published

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.

Free access — add to your briefcase to read the full text and ask questions with AI

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.

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

Pincite

199 F.2d 308 (Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

Related