Sears, Roebuck & Co. 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. 61 (1991,
aff'd in part,
ref'd in part, 972 F.2d 858 (7th Cir. 1992).] See also
AMERCO;
Harper Group.
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RF VI.B