PRUDENTIAL INSURANCE CO. OF AMERICA v. COMMISSIONER

Docket No. 45430-85.

90 T.C. 36 (1988)

THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 11, 1988.


Attorney(s) appearing for the Case

Michael F. Kelleher, for the petitioner.

Ellen Pilsecker, for the respondent.


OPINION

STERRETT, Chief Judge:

By notice of deficiency dated September 26, 1985, respondent determined deficiencies of $6,954,469 and $6,910,113 in petitioner's Federal income taxes for calendar years 1972 and 1973, respectively. After concessions, the only issue for decision is whether petitioner, in computing its gross investment income under section 804(b),1 must include certain prepayment penalties attributable to...

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