COHEN, Judge:
Respondent determined deficiencies of $83,769, $568, and $1,185 in petitioner's Federal income tax for 1981, 1982, and 1984, respectively. The sole issue raised in the petition and remaining for decision is whether petitioner is required to reduce its 1984 section 808(c)(1) policyholder dividends deduction by $40,762,000.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue...
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