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NATIONAL STATES INSURANCE CO. v. COMMISSIONER

Docket No. 17289-79.

81 T.C. 325 (1983)

NATIONAL STATES INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 19, 1983.

Attorney(s) appearing for the Case

W. Bruce Springer and Dave L. Cornfeld, for the petitioner.

Seymour I. Sherman, for the respondent.

WILBUR, Judge:

Respondent determined deficiencies and an addition to petitioner's Federal income taxes as follows:

                                  Addition to tax
Year               Deficiency    under sec. 6653(a)

1973 ............. $56,556.24
1974 ............. 169,687.01        $8,484.35
1975 ............. 157,315.55
1976 ............. 177,534.31

After concessions, the sole question presented for...

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