Ocean Drilling & Exploration Company, (On Behalf of Itself and Its Consolidated Subsidiaries) v. The United States

The United States appeals the judgment of the United States Claims Court 1 in Ocean Drilling & Exploration Co. v. United States, 24 Cl.Ct. 714 (1991). The issues appealed by the government are: (1) whether the Claims Court erred in holding that payments made by Ocean Drilling & Exploration Company (ODECO) (on behalf of its operating subsidiaries) to Mentor Insurance Limited (Mentor), a wholly-owned subsidiary of ODECO, constituted true insurance premiums that are deductible as business expenses under section 162 of the Internal Revenue Code of 1954, as amended (IRC), 2 and (2) if properly…