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R.V.I. GUARANTY CO. & SUBS. v. COMMISSIONER

Docket No. 27319-12.

145 T.C. 209 (2015)

R.V.I. GUARANTY CO., LTD. AND SUBSIDIARIES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 21, 2015.

Attorney(s) appearing for the Case

Dennis L. Allen , M. Kristan Rizzolo , and Daniel H. Schlueter , for petitioner.

Laurie A. Nasky and John Anthony Guarnieri , for respondent.

During 2006 petitioner R.V.I. Guaranty Co., Ltd., & Subsidiaries (RVI or petitioner) sold contracts for which the company's name is an acronym — "residual value insurance." The parties insured under these contracts included leasing companies, manufacturers, and financial institutions. The assets insured included passenger...

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