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MERIT LIFE INSURANCE COMPANY v. COMMISSIONER

Docket No. 13441-78.

52 T.C.M. 658 (1986)

T.C. Memo. 1986-480

Merit Life Insurance Company v. Commissioner.

United States Tax Court.

Filed September 25, 1986.

Attorney(s) appearing for the Case

Bernard J. Schoenberg and Michael Neil Gendelman, 50 California St., San Francisco, Calif., for the petitioner. Seymour I. Sherman, for the respondent.

Memorandum Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes as follows:

Year                      Deficiency

1972 ....................  $30,867.22
1973 ....................  344,269.10
1974 ....................  388,015.09
1975 ....................  681,259.08

After concessions, the only issue for decision involves the current deductibility vis-a-vis the amortization...

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