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

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    This document is a court case summary in which: 1) Philadelphia Title Insurance Company petitioned for review of a Tax Court decision regarding its tax liability on reserves required by Pennsylvania law for title insurance companies. 2) The Third Circuit Court of Appeals considered this same issue in a previous case of Wayne Title and Trust Co. v. Commissioner and saw no reason to distinguish this case from that one. 3) The Tax Court decision, finding the title insurance company liable for income taxes on the required reserves, was affirmed by the Third Circuit Court of Appeals.

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    Filed: 1952-10-22 Precedential Status: Precedential Citations: 199 F.2d 308 Docket: 10756

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    This document is a court case summary in which: 1) Philadelphia Title Insurance Company petitioned for review of a Tax Court decision regarding its tax liability on reserves required by Pennsylvania law for title insurance companies. 2) The Third Circuit Court of Appeals considered this same issue in a previous case of Wayne Title and Trust Co. v. Commissioner and saw no reason to distinguish this case from that one. 3) The Tax Court decision, finding the title insurance company liable for income taxes on the required reserves, was affirmed by the Third Circuit Court of Appeals.

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    3 views1 page

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

    Uploaded by

    Scribd Government Docs
    This document is a court case summary in which: 1) Philadelphia Title Insurance Company petitioned for review of a Tax Court decision regarding its tax liability on reserves required by Pennsylvania law for title insurance companies. 2) The Third Circuit Court of Appeals considered this same issue in a previous case of Wayne Title and Trust Co. v. Commissioner and saw no reason to distinguish this case from that one. 3) The Tax Court decision, finding the title insurance company liable for income taxes on the required reserves, was affirmed by the Third Circuit Court of Appeals.

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    of 1

    199 F.

    2d 308
    52-2 USTC P 9501

    PHILADELPHIA TITLE INS. CO.


    v.
    COMMISSIONER of INTERNAL REVENUE.
    No. 10756.

    United States Court of Appeals Third Circuit.


    Argued Oct. 16, 1952.
    Decided Oct. 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.

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