United States Tax Court May 28, 2013, 29527-07L, 27479-09 (Chapman Glen Limited v. Commissioner)

140 T.C. No. 15

UNITED STATES TAX COURT

CHAPMAN GLEN LIMITED, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket Nos. 29527-07L, 27479-09. Filed May 28, 2013.

In 1998, P was a foreign insurance company that elected under

I.R.C. sec. 953(d) to be treated as a domestic corporation for U.S.

Federal income tax purposes. G signed the election in G’s reported

capacity as P’s secretary.