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

U.S. Court of Appeals for the Third Circuit October 22, 1952

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

Goodrich, McLAUGHLIN, Per Curiam, Staley

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.

Reference

Status: Published