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PHOENIX MUTUAL LIFE INS. CO. v. COMMISSIONER

Docket No. 31993-87.

96 T.C. 497 (1991)

PHOENIX MUTUAL LIFE INSURANCE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1991.

Attorney(s) appearing for the Case

Arthur L. Bailey, Gerald A. Kafka, and J. Walker Johnson, for the petitioners.

Diane D. Helfgott, for the respondent.

SUPPLEMENTAL FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year ended December 31, 1980, in the amount of $6,223,612. The issues we consider in this supplemental opinion1 are: (1) Whether a reserve set aside by petitioner for insureds who were eligible, under group term life insurance policies, for extended insurance coverage without further payment...

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