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

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

Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Third Circuit · Decided October 22, 1952 · Goodrich, McLAUGHLIN, Per Curiam, Staley
199 F.2d 308 (Federal Reporter, Second Series)

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

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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