Penn Mutual Indemnity Co. v. Commissioner

GOODRICH, Circuit Judge.

This is an income tax case in which the Tax Court has sustained the Commissioner as against the taxpayer, 1959, 32 T.C. 653. The petitioner, as statutory liquidator of the Penn Mutual Indemnity Company, contests the decision of the Tax Court which determined a deficiency in tax for the year 1952 of $12,566.76. The taxpayer was, during its business lifetime, a mutual insurance company engaged in insuring casualty risks in Pennsylvania. There are two questions in the case. The first has to do with the jurisdiction of the Tax Court. The second has to do with the…