The Commissioner has determined a deficiency in petitioner's income tax for the year 1949 of $1,873.07. The deficiency is due to the addition to the net income reported by petitioner on its return of $8,143.77. That adjustment is explained in the deficiency notice as follows:
(a) It is held that premiums paid to a title insurance company are earned when received, and that reserves set up to meet future liabilities are not deductible from gross income (See Dallas Title...
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