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POLICY HOLDERS AGENCY, INC. v. COMMISSIONER

Docket No. 93719.

41 T.C. 44 (1963)

POLICY HOLDERS AGENCY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 10, 1963.

Attorney(s) appearing for the Case

Frank P. Meadows, Jr., for the petitioner.

Bernard A. Heeke, for the respondent.

OPINION

FORRESTER, Judge:

Respondent has determined a deficiency of $1,217.121 in petitioner's income tax for the calendar year 1958. The only issue before us is whether petitioner realized taxable income in 1958 based on the transfer of unclaimed premium refunds from a liability account to a surplus account.

All of the facts have been stipulated and are so found.

The petitioner, Policy Holders Agency,...

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