Philadelphia Title Ins. Co. v. Commissioner of Internal Revenue, 199 F.2d 308 (3d Cir. 1952)

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US Court of Appeals for the Third Circuit - 199 F.2d 308 (3d Cir. 1952) 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.


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.