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| IRS to Cancel Offer to Disallow 80% of Deductions on Broad-Based COLI; Will Go to Court for 100% (PDF) Internal Revenue Service [IRS]  [Official Guidance] Oct. 11, 2002 Excerpt: To date, the Service has successfully litigated three cases involving broad-based COLI transactions.... In all three cases, the courts denied the claimed interest deductions on the ground that the COLI plans lacked economic substance. |
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