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FIDELITY & DEPOSIT CO. v. PENNSYLVANIA

No. 114.

240 U.S. 319 (1916)

36 S.Ct. 298

60 L.Ed. 664

FIDELITY & DEPOSIT COMPANY OF MARYLAND v. COMMONWEALTH OF PENNSYLVANIA.

Supreme Court of United States.

Decided February 21, 1916.

Attorney(s) appearing for the Case

Mr. Charles Markell, Jr., with whom Mr. Charles F. Patterson was on the brief, for plaintiff in error.

Mr. William M. Hargest, with whom Mr. Francis Shunk Brown, Attorney General of the State of Pennsylvania, was on the brief, for defendant in error.

MR. JUSTICE McREYNOLDS delivered the opinion of the court.

We are asked to reverse a judgment of the Supreme Court of Pennsylvania which denied plaintiff in error's claim that in becoming surety upon bonds required by the United States it acted as a Federal instrumentality and was not subject to taxation on the premiums received. 244 Pa. St. 67.

Incorporated under the laws of Maryland, the Fidelity & Deposit Company...

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