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

Philadelphia Title Ins. Co. v. Comm'r of Internal Revenue, 199 F.2d 308 (3d Cir. 1952)
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Court
Court of Appeals for the Third Circuit · U.S. Courts of Appeals
Decided
October 22, 1952
Docket
No. 10756
Judges
Goodrich, McLAUGHLIN, Per Curiam, Staley
Citations
199 F.2d 308

Opinion — Per Curiam

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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Wayne Title & Trust Co. v. Comm'r of Internal Revenue, 195 F.2d 401 (3d Cir. 1952) 15

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