NORTH WEST LIFE ASSURANCE CO. OF CAN. v. COMMR.

Docket No. 4694-94.

107 T.C. 363 (1996)

THE NORTH WEST LIFE ASSURANCE COMPANY OF CANADA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 12, 1996.


Attorney(s) appearing for the Case

Jerome B. Libin, James V. Heffernan, Richard J. Safranek, and Steven M. Sobell, for petitioner.1

Gary D. Kallevang, Diane D. Helfgott, Charles M. Ruchelman, Elizabeth U. Karzon, George Soba, and Sharon J. Bomgardner, for respondent.


HAMBLEN, Judge:

Respondent determined deficiencies in petitioner's Federal income and branch profits tax for the taxable years 1988, 1989, and 1990, in the amounts of $518,102, $23,730, and $71,662, respectively.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The sole issue for decision is whether...

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