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GERLING INTERNATIONAL INSURANCE v. COMMR.

Docket No. 26765-83.

87 T.C. 679 (1986)

GERLING INTERNATIONAL INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 24, 1986.

Attorney(s) appearing for the Case

Lawrence Gerzog, for the petitioner.

David Brodsky, for the respondent.

OPINION

TANNENWALD, Judge:

This case is again before us on cross motions for summary judgment. The parties agree (and we concur) that, in the present posture of the case, there are no genuine issues of material fact involved; consequently, we may dispose of the case by decision as a matter of law. Rule 121, Tax Court Rules of Practice and Procedure.

The factual background, which provides the foundation...

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