Lessons Learned From The "Avrahami" Case

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There have been many articles and much information on Avrahami v. Comm’r and Feedback Ins. Co., Ltd. v. Comm’r, 149 T.C. 7 (2017). Within the lengthy court opinion, there are many lessons and discussions. So, what can we learn from this case? First and most important is that the Avrahamis’ captive was not operating like an insurance company. As such, it should be no surprise that a company that is not acting as an insurance company would not receive nor be entitled to…