The Harper Group v. Commissioner
One of three cases decided in January 1991 in which premiums paid to wholly
owned insurance companies were deemed deductible expenses. Substantial unrelated
business, among other tests, was critical. [96 T.C. 45 (1991,
aff'd, 979 F.2d
1341 (9th Cir. 1992).] See also
Sears;
AMERCO.
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