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RELIANCE BENEFIT ASSOCIATION v. COMMISSIONER

Docket No. 107904.

2 T.C. 15 (1943)

RELIANCE BENEFIT ASSOCIATION, A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 1, 1943.

Attorney(s) appearing for the Case

A. Henderson Stockton, Esq., for the petitioner.

Samuel Taylor, Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

The Commissioner determined deficiencies in income tax for the years 1937 and 1938 in the respective amounts of $253.69 and $246.09. He held that petitioner was not a life insurance company because none of its reserve funds were held for the fulfillment of life insurance contracts within the meaning of section 201 of the Revenue Acts of 1936 and 1938 and the regulations promulgated thereunder. The facts are found as stipulated...

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