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COLUMBIA CASUALTY COMPANY v. COMMISSIONER

Docket No. 22321.

10 T.C.M. 371 (1951)

Columbia Casualty Company v. Commissioner.

United States Tax Court.

Entered April 30, 1951.

Attorney(s) appearing for the Case

Edward S. Coons, Jr., Esq., 1 Park Ave., New York, N. Y., for the petitioner. William A. Schmitt, Esq., for the respondent.

Memorandum Opinion

HARRON, Judge:

The Commissioner has determined a deficiency of $17,689.34 in the petitioner's excess profits tax for the year 1943.

The issue in this proceeding is whether, in the computation of "losses incurred" under section 204 (b) (6), the petitioner may use as its unpaid outstanding losses on liability and workmen's compensation insurance as of December 31, 1943, the amounts required...

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