Avrahami v. Comm'r
United States Tax Court
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 I.R.C. section 831(b) to be treated as a small insurance company and under I.R.C. section 953(d) to be taxed as a domestic corporation were invalid, as the amounts…
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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 I.R.C. section 831(b) to be treated as a small insurance company and under I.R.C. section 953(d) to be taxed as a domestic corporation were invalid, as the amounts paid did not qualify as insurance premiums for federal income tax purposes. R also determined that amounts transferred…
1Opinion of the Court
BENYAMIN AVRAHAMI AND ORNA AVRAHAMI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
FEEDBACK INSURANCE COMPANY, LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Avrahami v. Comm'r
Docket Nos. 17594-13, 18274-13.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 40; 149 T.C. No. 7;
August 21, 2017, Filed
Decisions will be entered under Rule 155.
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…
2Cases cited48 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Beaver v. CommissionerUnited States Tax Court · 1970
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Foster v. Comm'rUnited States Tax Court · 1983
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