Insurance Risk
Investment risk not sufficient
Fortuity required = a chance occurrence Risk of an economic loss that may occur as a result of a fortuitous occurrence of a stated contingency R.V.I. Guar. Co. v. Commissioner , 145 T.C. 209 (2015) Non captive Tax Court case that expanded or clarified business risks that may be captured within an insurance contract, specifically allowing residual value insurance as valid insurance
AEC EXECUTIVE ROUNDTABLE
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