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ALLSTATE FIRE INSURANCE CO. v. COMMISSIONER

Docket No. 4812-64.

47 T.C. 237 (1966)

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

United States Tax Court.

Filed December 2, 1966.

Attorney(s) appearing for the Case

Charles W. Davis, William A. Cromartie, and Lawrence M. Dubin, for the petitioner.

Nelson E. Shafer, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined deficiencies in petitioner's income taxes for the years ended December 31, 1958, and December 31, 1959, in the respective amounts of $149,433.51 and $34,158.79. Petitioner has claimed overpayments for the same years in the amounts of $90,269.61 and $26,771.48, respectively.

Certain adjustments were either uncontested or have been resolved by agreement of the parties. These will be given effect in...

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