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NOTES 941 Tax Lawyer, Vol. 53, No. 4 NOTE SHAM TRANSACTION DOCTRINE APPLIED TO THE OFFSHORE REINSURANCE INDUSTRY: UNITED PARCEL SERVICE OF AMERICA, INC. V. COMMISSIONER In United Parcel Service of America, Inc. v. Commissioner,1 the Tax Court held that the taxpayer must include “excess value charges”2 (“EVCs”) in its income for the tax year 1984. The case involved a complex scheme whereby the taxpayer collected the EVCs, forwarded them to an insurer, and the insurer forwarded the proceeds to...