American Title Co. v. Commissioner of Internal Revenue

This case is here on the taxpayer’s petition to review a decision of the United States Board of Tax Appeals sustaining and enlarging a deficiency tax assessed against it by the Commissioner of Internal Revenue. There are two questions:

1. Whether premiums paid a title insurance company for policies guaranteeing titles are earned when paid and constitute taxable income within the meaning of section 204 of the Revenue Act of 1928 (45 Stat. 791, 844 [26 USCA § 2204]).

2. Whether reserves set up by a title insurance company under the laws of Pennsylvania (Act April 26, 1929, P. L. 834 [40 PS Pa. §§…