HALPERN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $40,492.04 and $42,312.02, for 1983 and 1984, respectively.
The issues for consideration are: (1) Whether purported insurance premiums paid by a petitioner subsidiary in 1983 and 1984 were payments for "insurance"; and (2) if so, whether such payments were ordinary expenses deductible in those years.
Unless otherwise noted, all section references...
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