IRS's captive appeals fall on deaf ears; mortgage issue is lost as well.: An article from: The Tax Adviser |  | Authors: Addison H. Shuster, James S. Stavris Brand: The Gale Group Category: Book
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ASIN: B00091KRI0
Publication Date: April 1, 1993 Availability: Available for download now
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Product Description This digital document is an article from The Tax Adviser, published by American Institute of CPA's on April 1, 1993. The length of the article is 862 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The IRS has lost appeals in three cases, against Sears Roebuck, AMERCO and Harper, where subsidiary insurers sold insurance to parent companies. The Seventh Circuit court discarded the LeGierse risk distribution test that had been in use since 1941 in favor of examining the relationship. The court found that the captive subsidiaries had operated in a sufficiently objective manner to warrant the allowance of the relationship. The same court also ruled against the IRS in a related suit against Sears regarding deductions for reserves established for claims that had not been incurred.
Citation Details Title: IRS's captive appeals fall on deaf ears; mortgage issue is lost as well. Author: Addison H. Shuster Publication: The Tax Adviser (Magazine/Journal) Date: April 1, 1993 Publisher: American Institute of CPA's Volume: 24 Issue: n4 Page: 232(2)
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