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C. P. A. CO. v. COMMISSIONER

Docket No. 3963.

7 T.C. 912 (1946)

C. P. A. COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 2, 1946.

Attorney(s) appearing for the Case

Raymond H. Berry, Esq., Ralph W. Barbier, Esq., and Arthur L. Evely, Esq., for the petitioner.

A. J. Friedman, Esq., for the respondent.

The respondent determined deficiencies in income tax against C. P. A. Co. for the years 1938 and 1939 in the respective amounts of $16,303.57 and $30,974.51.

The only issue now in controversy is whether or not the petitioner, in computing its underwriting income for the years in question, is entitled to adjust such income by deducting, as "unearned premiums" under section 204 (b) (5) of the Revenue Act of 1938 and the Internal...

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