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HARPER GROUP v. C.I.R.

No. 91-70576.

979 F.2d 1341 (1992)

The HARPER GROUP, and Includible Subsidiaries, Petitioners-Appellees, v. COMMISSIONER of INTERNAL REVENUE SERVICE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided November 5, 1992.

Attorney(s) appearing for the Case

John A. Dudeck, Jr., and Gary R. Allen, U.S. Dept. of Justice, Tax Div., Appellate Section, Washington, D.C., for respondent-appellant.

Paul J. Sax and William L. Riley, Orrick, Herrington & Sutcliffe, San Francisco, Cal., for petitioner-appellee.

Before: POOLE, FERNANDEZ, and T.G. NELSON, Circuit Judges.

FERNANDEZ, Circuit Judge:

The Harper Group (Harper) and certain of its domestic subsidiaries purchased insurance policies from Rampart Insurance Co., Ltd. (Rampart) and deducted the premiums for income tax purposes. Rampart is a wholly owned subsidiary of two of Harper's subsidiaries. The Commissioner of Internal Revenue (Commissioner) determined that because of the relationship among the parties the transactions did not constitute insurance. A notice of deficiency...

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