January 12, 1987
Specialty Rulings Directorate G. Thornley (613) 957-2130
RE: Section 148
This is in reply to your Round Trip Memorandum of November 3, 1986 asking us to review your series of calculations related to the proceeds of disposition on maturity of a life insurance policy owned by XXXX.
As our review indicates an error in the way XXXX has determined the taxable gain on surrender of XXXX life insurance policy we are referring the file with your calculations to the Industry Studies Section of the Audit Programs Directorate. Mr. R. Campbell is the acting supervisor of the section. We will probably be in contact with you in the near future.
for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch