# Sears, Roebuck & Co. v. Commissioner

> United States Tax Court · January 24, 1991 · 96 T.C. 61

URL: https://www.frixlaw.com/law-library/cases/4486536

## Case

- **Full name:** Sears, Roebuck and Co. and Affiliated Corporations v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** January 24, 1991
- **Citations:** 96 T.C. 61; 96 T.C. No. 5; 1991 U.S. Tax Ct. LEXIS 5
- **Precedential status:** Published
- **Opinion:** Concurrence by Chabot
- **Judges:** Cohen,Korner,Shields,Hamblen,Swift,Gerber,Wright,Parr,Colvin,Halpern,Wells,Ruwe,Nims,Jacobs,Chabot,Whalen
- **Cited by:** 30 later opinions in the Frix Law Library

## Citator (automated)

- **Red flag:** 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).
- Negative treatments: 2
- Distinguished by: 0
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4486536

## Opinion text

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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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4486536. Public record. Not legal advice.