- 45 - 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)Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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