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CLOUGHERTY PACKING CO. v. C.I.R.

No. 85-7707.

811 F.2d 1297 (1987)

CLOUGHERTY PACKING COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 3, 1987.

Attorney(s) appearing for the Case

Brian J. Seery, Los Angeles, California, for petitioner-appellant.

Gayle P. Miller, Gary R. Allen, Washington, D.C., for respondent-appellee.

Before ANDERSON, PREGERSON and REINHARDT, Circuit Judges.

REINHARDT, Circuit Judge:

We are presented with another version of a not so novel question: Are amounts paid as "insurance premiums" by a parent corporation to its "captive insurance company"1 subsidiary deductible for purposes of federal income taxation? This latest twist, like the previous case we considered, Carnation Co. v. Commissioner, 640 F.2d 1010 (9th Cir.), cert. denied, 454 U.S...

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