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HOLYOKE MUTUAL FIRE INSURANCE CO. v. COMMISSIONER

Docket No. 51780.

28 T.C. 112 (1957)

HOLYOKE MUTUAL FIRE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 23, 1957.

Attorney(s) appearing for the Case

Roger P. Stokey, Esq., Nicholas S. Kiefer, Esq., and Charles D. Post, Esq., for the petitioner.

Paul J. Henry, Esq., for the respondent.

TIETJENS, Judge:

The respondent determined a deficiency in income tax for the calendar year 1950 in the amount of $4,695.28. The sole issue is whether the petitioner was during that year an insurance company other than mutual, and taxable under section 204, Internal Revenue Code of 1939, or a mutual insurance company other than life or marine, and taxable under section 207 of such Code. Some facts are stipulated.

FINDINGS OF FACT.

The facts...

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