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relating to premiums received by Parthenon from members of the
affiliated group on their consolidated returns for the years in
issue. In the petitions filed in the instant case, petitioners
claim that Parthenon is entitled to be treated as an insurance
company for the years in issue, that petitioners are entitled to
deduct premiums they paid to Parthenon for insurance coverage for
those years, and that Parthenon is entitled to deduct the
increase in its reserves associated with those premiums, in
amounts of premiums not less than the following:
Professional Reinsurance
and General of Workers'
Liability Compensation
Year Insurance Insurance Total
1981 $15,571,167 $3,404,406 $18,975,573
1982 21,742,220 4,514,782 26,257,002
1983 17,630,680 5,364,185 22,994,865
1984 12,016,909 2,598,288 14,615,197
1985 36,796,826
1986 80,247,632
1987 1
1988 1
1Specific amounts were not stated in the petitions.
Petitioners claim that overpayments of tax with respect to
the transactions with Parthenon result in tax in issue for the
years in issue as follows:
TYE Increase (Decrease) in Tax
1981 ($8,703,732)
1982 (12,247,563)
1983 (11,520,738)
1984 (6,128,314)
1985 (22,228,950)
1986 (52,934,878)
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