149 T.C. No. 7

BENYAMIN AVRAHAMI AND ORNA AVRAHAMI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

FEEDBACK INSURANCE COMPANY, LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

UNITED STATES TAX COURT. Docket Nos. 17594-13, 18274-13. Filed August 21, 2017.

Ps claimed deductions under I.R.C. section 162 on their 2009 and 2010 tax returns for amounts paid by their passthrough entities to captive insurance company C wholly owned by PW and to off-shore company A which reinsured a portion of its risk with C. R denied the deductions and determined that C’s elections under […]

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