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Income Tax Keyed to Bankman
Winn-Dixie Stores, Inc. v. Commissioner
Citation:
254 F.3d 1313 (11th Cir. 2001), cert. denied, 535 U.S. 986 (2002)Facts
Petitioner embarked on a COLI program in 1993 wherein it purchased whole life insurance policies on almost all of its full-time employees, with itself as the sole beneficiary of the policies. Petitioner would borrow against its policies’ account value at an interest rate over 11%. The high interest rate and administrative fees led to Petitioner losing money on the program. However, the deductions in the tax code yielded a benefit that was projected to reach into the billions over the course of 60 years. The tax code changed in 1997 and Petitioner backed away from this practice. The Commissioner of Internal Revenue asserted a deficiency against Petitioner for the 1993 tax year, finding that the COLI program was functionally a sham transaction.
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