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WINN-DIXIE STORES, INC. & SUBS. v. COMMISSIONER

Docket No. 5382-97.

113 T.C. 254 (1999)

WINN-DIXIE STORES, INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

Filed October 19, 1999.

Attorney(s) appearing for the Case

Michael J. Henke, Tegan M. Flynn, Cary D. Pugh, Thomas Crichton IV, Robert H. Cox, and Thomas P. Marinis, Jr., for petitioner.

Nancy B. Herbert, Jeffrey L. Bassin, James D. Hill, and Michelle A. Missry, for respondent.

RUWE, Judge:

Respondent determined a deficiency of $1,599,176 in petitioner's Federal income tax for its tax year ending June 30, 1993. After concessions, the issue is whether deductions petitioner claimed for policy loan interest and administrative fees associated with certain of petitioner's corporate-owned life insurance (COLI) policies are deductible.

Unless otherwise indicated, all section references are...

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