Stevedoring Services of America, Inc. and Subsidiaries - Page 7

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               Services Group filed a petition in this Court for its fiscal           
          years ended January 31, 1977; January 31, 1978; and January 31,             
          1979.  One of the contested issues was the deductibility of the             
          Hanseatic payments.  The case was resolved by a Stipulation of              
          Settlement dated September 24, 1986.  The Internal Revenue                  
          Service (IRS) and Services Group resolved the proposed                      
          disallowance of premium deductions for the fiscal years ended               
          January 30, 1981; January 29, 1982; January 28, 1983; January 27,           
          1984; and January 25, 1985, on terms similar to the Stipulation             
          of Settlement dated September 24, 1986.                                     
               The IRS audited Crescent Wharf's 1982 income tax return and            
          disallowed claimed insurance premium deductions made to Executive           
          through INA.  The case was settled on terms similar to the                  
          Hanseatic settlement.  The parties resolved the proposed                    
          disallowance of premium deductions for the fiscal years ended               
          January 31, 1986, and January 30, 1987, by agreeing to treat 75             
          percent of the arrangements with Eagle as insurance for tax                 
          purposes and, therefore, to allow 75 percent of the payments to             
          Eagle in each year as deductible insurance premiums in the year             
          paid.  The remaining 25 percent was disallowed insurance                    
          treatment.                                                                  
               The amounts disallowed as insurance deductions in years                
          prior to the year ended January 26, 1990, were treated as capital           
          contributions to Hanseatic and Eagle, respectively.                         






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