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Sears V Commissioner

Sears 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, rev'd in part, 972 F.2d 858 (7th Cir. 1992).]

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