United States Board of Tax Appeals September 30, 1937, Docket No. 78000 (Pacific Employers Insurance Co. v. Commissioner)

*587OPINION.

Sternhagen :

1. The petitioner’s first contention is that its deduction for losses should be not $611,245.39, as taken by it on its return, but $752,838.04, as shown on its annual statement filed with the California insurance commissioner.