Capital Blue Cross and Subsidiaries - Page 54

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          ignores the human elements associated with the group contracts              
          and whether they will be renewed or terminated by the group                 
          sponsors.                                                                   

          Conclusion                                                                  
               Petitioner is not entitled to the claimed $4 million in loss           
          deductions relating to the 376 health insurance group contracts             
          that were terminated in 1994.                                               

                                             Decision will be entered                 
                                        for respondent.                               

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