COLOGNE LIFE REINSURANCE CO. v. COMMISSIONER

Docket No. 10337-81.

80 T.C. 859 (1983)

COLOGNE LIFE REINSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 12, 1983.


Attorney(s) appearing for the Case

Carolyn P. Chiechi, Francis M. Gregory, Jr., Michael A. Bell, and Dennis L. Allen, for the petitioner.

Evelyn E. Small, for the respondent.


OPINION

WHITAKER, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes as follows:

              Taxable year                  Deficiency

                 1974 ..................    $123,141
                 1975 ..................     123,433
                 1976 ..................     133,077
                 1977 ..................     170,683
...

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