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MANUFACTURERS LIFE INS. CO. v. UNITED STATES

No. 43589.

32 F.Supp. 284 (1940)

MANUFACTURERS LIFE INS. CO. v. UNITED STATES.

Court of Claims.

April 1, 1940.

Attorney(s) appearing for the Case

John W. Townsend, of Washington, D. C. (A. R. Serven, of Washington, D. C., on the brief), for plaintiff.

George H. Foster, of Washington, D. C., and Samuel O. Clark, Jr., Asst. Atty. Gen. (Robert N. Anderson and Fred K. Dyar, both of Washington, D. C., on the brief), for defendant.

Before WHALEY, Chief Justice, and GREEN, LITTLETON, WILLIAMS, and WHITAKER, Judges.

WHITAKER, Judge.

The plaintiff is a foreign life insurance company. During both of the taxable years in question it received interest exempt from taxation in the amount of $4,250, and it also received in one year dividends in the amount of $12,550, and in the other year, in the amount of $37,722.25. In computing its net income from sources within the United States the Commissioner deducted from its gross income from all sources the amount of this interest and dividends...

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