Lincoln Mortgage & Title Guaranty Co. v. Commissioner of Internal Revenue

DAVIS, Circuit Judge.

This appeal involves the" liability of the taxpayer, the Lincoln Mortgage & Title Guaranty Company, for income taxes for the years 1926 and 1927.

*586The taxpayer was incorporated under the insurance laws of the state of New Jersey and was operated under the direction and supervision of the department of banking and insurance of that state.

The taxpayer was principally engaged in the business of lending money on bonds secured by mortgages on real estate. On approval of an application for a loan, the taxpayer would take a mortgage and a 6 per cent, bond from the borrower and…