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Abstract: 

Three recent rulings are the result of an earlier focus of the IRS on entities claiming to be exempt insurance companies under Section 501(c)(15). The companies were trying to maintain the exempt status that the Service initially granted them. Entities seeking to create captive insurance companies should study these rulings to find out what the Service will look for during examinations. One of the rulings discussed below was not technically a captive, though seems to have been largely conducted as a business to supplement the income of its individual owner.

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Affiliations:  1: Journal Staff.