Penn Mut. Life Ins. v. C.I.R

Full title: PENN MUTUAL LIFE INSURANCE COMPANY, Petitioner, v. COMMISSIONER OF…

Court: Circuit Court of Appeals, Third Circuit

Date published: Oct 28, 1937

92 F.2d 972 (3d Cir. 1937)

Opinion

No. 6046.

October 28, 1937.

Petition for Review from a Decision of the United States Board of Tax Appeals.

Robert Dechert, of Philadelphia, Pa., for petitioner.

James W. Morris, Asst. Atty. Gen., and Sewall Key, Norman D. Keller, and Edward H. Horton, Sp. Assts. to Atty. Gen., for respondent.

Before THOMPSON and BIGGS, Circuit Judges, and DICKINSON, District Judge.

PER CURIAM.

The issues presented in the case at bar are identical with those in Penn Mut. Life Ins. Company v. Commissioner of Internal Revenue (C.C.A.) 92 F.2d 962. In view of our full discussion of the issues in the opinion filed in that case, we deem a lengthy opinion unnecessary. We therefore remand this case to the Board of Tax Appeals, with instructions to redetermine the tax deficiences of the taxpayer for the year in question in accordance with the principles of law enunciated in the cited case.