Philadelphia Saving Fund Society v. United States

KIRKPATRICK, District Judge.

This is a suit to recover federal income taxes in the amount of $139,200.33, alleged to have been erroneously assessed, paid by the plaintiff for the year 1952. All of the relevant facts appear in a stipulation. Both parties have filed motions for judgment on the pleadings, or for summary judgment.

The stipulation is, in . substance, as follows: The plaintiff is a mutual savings bank whose deposits are insured under the Federal Deposit Insurance Act (12 U.S.C.A. § 1811 et seq.). It files its income tax returns and keeps its books on the accrual basis. Under Section…