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HARPER GROUP v. COMMISSIONER

Docket No. 33761-85.

96 T.C. 45 (1991)

THE HARPER GROUP AND INCLUDIBLE SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 24, 1991.

Attorney(s) appearing for the Case

Paul J. Sax, William L. Riley, and Andrew W. Stroud, for the petitioners.

Eugene H. Ciranni and Cynthia K. Hustad, for the respondent.

JACOBS, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

   Year                                        Deficiency

   1981 ..................................     $5,224,177
   1982 ..................................      2,114,098
   1983 ..................................      3,439,865

After concessions, the issues for decision are: (1) Whether insurance premiums paid...

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