Memorandum Findings of Fact and Opinion
LEECH, Judge:
The petitioner seeks a redetermination of income tax deficiencies in the amount of $11,373.10 for the calendar year 1938 and $14,708.04 for the year 1939. The sole issue is whether or not the petitioner is taxable as a life insurance company within the purview of sections 201, 202 and 203 of the Revenue Act of 1938. The petitioner filed its income tax returns for the years involved on Form 1120-L with...
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