Rev. Rul. 78-338

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Premiums paid to association captives are deductible if there is a true sharing of risk between participants in, or owners of, an association captive. Facts indicated 31 unrelated participants, no one of which accounted for over 5% of aggregate premiums. It was modified by Rev. Rul. 2001-31, then further modified by Rev. Rul. 2002-91.