The respondent determined deficiencies in income tax for the calendar years ended December 31, 1940 and 1941, in the respective amounts of $28,152.17 and $10,754.50. The issues are whether the petitioner was exempt from Federal corporation income and excess profits taxes under section 101 (11) of the Internal Revenue Code as a mutual insurance company, and, if it was not so exempt, whether it was a mutual insurance company entitled under section 207 (c) (3) to deduct certain...
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