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GERLING INTERNATIONAL INSUR. CO. v. COMMR.

Docket No. 26765-83.

98 T.C. 640 (1992)

GERLING INTERNATIONAL INSURANCE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 27, 1992.

Attorney(s) appearing for the Case

Jules Ritholz and Walter P. Stasiuk, for petitioner.

Anne Hintermeister and Lawrence Hoch, for respondent.

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes of $885 for the taxable year ending December 31, 1974, $2,043 for the taxable year ending December 31, 1975, $1,439,676 for the taxable year ending December 31, 1976, $1,917,174 for the taxable year ending December 31, 1977, and $2,503,934 for the taxable year ending December 31, 1978. The issues for decision are: (1) Whether petitioner should be required, under section...

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