- 2 -
and Eagle Pacific Insurance Company (Eagle), petitioners are
entitled to an insurance premium deduction in the fiscal year
ended January 26, 1990, for payments made to Hanseatic in the
fiscal years ended 1977 through 1985 and to Eagle in the fiscal
years ended 1986 and 1987, in excess of deductions previously
allowed for Longshoremen's and Harbor Workers' Compensation Act
Amendments of 1984 (LHW Act), Pub. L. 98-426, 98 Stat. 1639, 33
U.S.C. sec. 901 (1994), claims paid.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to Tax Court Rules of Practice and
Procedure.
Background
The material facts have been stipulated, and the stipulated
facts are incorporated herein by this reference. The parties
have stipulated to the detail and characterization of various
contracts entered into during years prior to the one in issue.
Because those details are not disputed and do not affect our
analysis of the issue for decision, we have not burdened this
opinion with them.
At the time the petition was filed, the principal place of
business of Stevedoring Services of America, Inc. (Stevedoring),
was Seattle, Washington. Stevedoring and its wholly owned
subsidiaries primarily engage in stevedoring operations.
Stevedoring and its includable subsidiaries (petitioners) filed a
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011