Opinion

Sears, Roebuck & Co. v. Commissioner

96 T.C. 61
96 T.C. No. 5
1991 U.S. Tax Ct. LEXIS 5

Court: United States Tax Court
Filed: Jan 24, 1991
Status: Published
Author: Chabot
On the bench: Cohen,Korner,Shields,Hamblen,Swift,Gerber,Wright,Parr,Colvin,Halpern,Wells,Ruwe,Nims,Jacobs,Chabot,Whalen
Cited by: 30 cases

Reversed on other grounds by Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant, 972 F.2d 858 (1992)

approximately 99.75% of insured risks were outside risks

How later courts described this case

approximately 99.75% of insured risks were outside risks

Written by the judges who cited it.

The opinion

Chabot, J., concurring in part and dissenting in part: I agree with the majority on the mortgage guarantee insurance issue for reasons stated in the majority opinion, but I respectfully dissent on the insurance premiums issue, and agree with Judge Whalen’s dissenting opinion on this issue.

PARKER, J., agrees with this opinion.

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