UNION CENTRAL LIFE INS CO. v. COMMISSIONER

Docket No. 2094-78.

84 T.C. 361 (1985)

THE UNION CENTRAL LIFE INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 11, 1985.


Attorney(s) appearing for the Case

William R. Seaman, Jerry L. Cowan, and Thomas C. Rink, for the petitioner.

Conley G. Wilkerson, for the respondent.


SUPPLEMENTAL OPINION

WILES, Judge:

The Court of Appeals for the Sixth Circuit remanded this case for us to determine whether the payments of Ohio franchise taxes by petitioner during 1972, 1973, and 1974 were directly related to the production of investment income.

The issue in this case is legal. However, to the extent necessary we find the facts to be as set forth in the findings of fact in our opinion...

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