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HOME GROUP, INC. v. COMMISSIONER

Docket No. 17739-82.

92 T.C. 940 (1989)

THE HOME GROUP, INC., AS AGENT UNDER THE PROVISIONS OF TREASURY REGULATION SECTION 1.1502-77(D) FOR CITY INVESTING CO. AND THE CONSOLIDATED GROUP OF WHICH CITY INVESTING COM. WAS THE COMMON PARENT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 10, 1989.

Attorney(s) appearing for the Case

William L. Goldman, John S. Breckinridge, Jr., and F. Brook Voght, for the petitioner.

Daniel A. Guy, Jr., and Maureen Nelson, for the respondent.

OPINION

GERBER, Judge:

This matter is before the Court on respondent's motion to set aside our approval of petitioner's appeal bond. On January 15, 1987, we held that Home Insurance Co. (sometimes referred to as Home) and Home Indemnity Co. (Indemnity), members of the consolidated group of corporations of which City Investing Co. was the common parent, were not entitled to deductions for insurance sales commissions associated with deferred and unearned...

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