PHILADELPHIA TITLE INSURANCE CO. v. COMMISSIONER

Docket No. 25942.

17 T.C. 1068 (1951)

PHILADELPHIA TITLE INSURANCE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 29, 1951.


Attorney(s) appearing for the Case

Herman H. Greenberg, Esq., for the petitioner.

Lester H. Salter, Esq., for the respondent.


OPINION.

MURDOCK, Judge:

The Commissioner determined deficiencies of $1,899.14 in income tax and $2,970.35 in excess profits tax for 1945, and a deficiency in income tax of $7,075.38 for 1946. The issues for decision are whether amounts credited in each year to a reserve for reinsurance are properly a part of income and whether the petitioner may deduct on an accrual basis or only on a cash basis Pennsylvania stock taxes imposed upon its shareholders...

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