- 74 -
with significant future benefits. See U.S. Bancorp & Consol.
Subs. v. Commissioner, 111 T.C. 231 (1998). Even if one were to
agree with the majority that the entrance and exit fees were paid
in order to terminate burdensome insurance premium obligations,
the entrance and exit fees would still fall within the rubric of
long-term benefits.
For all the foregoing reasons, I respectfully dissent.
RUWE, WHALEN, and GALE, JJ., agree with this dissenting
opinion.
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