- 6 - relevant to this case, Eagle held licenses to conduct the insurance business in the States of Washington and Alaska. Beginning on January 1, 1985, and through the subsequent years relevant to this case, the stevedoring affiliates of Services Group insured their LHW Act risks with Eagle on a direct basis. After the splitup, Eagle continued to insure all of petitioners' LHW Act risks. In the fiscal years ended January 31, 1986, and January 30, 1987, Eagle received approximately 29 percent and 41 percent, respectively, of its premiums from unrelated insureds. The transactions among Services Group and its subsidiaries and Eagle that were not treated as insurance for tax purposes in 1985 through 1987 would have been treated as insurance transactions in those years if the transactions had been entered into with nonaffiliated parties. Audit History Services Group and its affiliates claimed deductions for payments, directly or indirectly, to Hanseatic, Norwesco, Executive, and Eagle as insurance premiums under section 162 in the years paid. Services Group and its subsidiaries were audited for each of its fiscal years ended January 31, 1977, through January 25, 1987, except the fiscal year ended January 25, 1980. As a result of the audits, respondent proposed to disallow insurance premium deductions for payments made in those years directly or indirectly to Hanseatic, Norwesco, Executive, and Eagle.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011