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STEVEDORING SERVICES OF AMERICA, INC. v. COMMISSIONER

Docket No. 13399-95.

73 T.C.M. 2487 (1997)

T.C. Memo. 1997-160

Stevedoring Services of America, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed March 31, 1997.

Attorney(s) appearing for the Case

P. Bruce Wright, New York, N.Y., George R. Abramowitz, and Diana E. Buckley, for the petitioners. Terri A. Merriam and Keith G. Medleau, for the respondent.

MEMORANDUM OPINION

COHEN, Chief Judge:

Respondent determined a deficiency in petitioners' Federal income tax of $2,018,147 for the fiscal year ended January 26, 1990.

The issue for decision is whether, upon disaffiliation from Hanseatic Eastern Insurance Company (Bermuda), Ltd. (Hanseatic) and Eagle Pacific Insurance Company (Eagle), petitioners are entitled to an insurance premium deduction in the fiscal year ended January 26, 1990, for payments...

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