Philadelphia Title Ins. v. C.I.R

Full title: PHILADELPHIA TITLE INS. CO. v. COMMISSIONER OF INTERNAL REVENUE

Court: United States Court of Appeals, Third Circuit

Date published: Oct 22, 1952

199 F.2d 308 (3d Cir. 1952)

Opinion

No. 10756.

Argued October 16, 1952.

Decided October 22, 1952.

Herman H. Greenberg, Philadelphia, Pa., for petitioner.

Harry Marselli, Washington, D.C. (Ellis N. Slack, Acting Asst. Atty. Gen., Lee A. Jackson, Washington, D.C., on the brief), for respondent.

Before GOODRICH, McLAUGHLIN and STALEY, Circuit Judges.

PER CURIAM.

This petition for review of a decision by the Tax Court raises the question of the liability for income tax upon the reserve required of a title insurance company under the Pennsylvania law. We considered the question at length in Wayne Title and Trust Co. v. Commissioner, 3 Cir., 1951, 195 F.2d 401, and we are not convinced that the taxpayer has shown us any reason for distinguishing that case from this.

The decision of the Tax Court is affirmed.