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ANCHOR NATIONAL LIFE INS. CO. v. COMMISSIONER

Docket No. 40452-84.

93 T.C. 382 (1989)

ANCHOR NATIONAL LIFE INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 28, 1989.

Attorney(s) appearing for the Case

John L. Snyder, Ethel R. Kaplan, Paul S. Caselton, George R. Goodman, and Francis O. McDermott, for the petitioner.

Judy Jacobs Miller, for the respondent.

PARKER, Judge:

Respondent determined a deficiency of $4,160,820 for the taxable year 1979 and $3,227,095 for the taxable year 1980. The issues for decision1 are:

(1) Whether the amounts payable by petitioner on certificates of contribution that it issued to its parent corporation are deductible as interest;

(2) Whether petitioner may reduce its gross premium income by the...

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