Lamana-Panno-Fallo Industrial Ins. v. Commissioner

SIBLEY, Circuit Judge.

The petitioner seeks review of a decision of the Board of Tax-Appeals which upheld the Commissioner in deciding that for the calendar years 1936 and 1937 petitioner was not entitled to the favorable income tax treatment given life insurance companies under Sections 201-203 of the Revenue Act of 1936; and in taxing it under Section 204, 26 U.S.C.A. Int.Rev.Acts, pages *58898-899, and page 900. The decision is defended on the ground that the reserves held by petitioner against its policies were not those “required by law”, as mentioned in Section 203, and in Regulation 94, Art.…