- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011