Settled Cases

  • Premera Blue Cross v. United States, Docket No. 05-01301-JCC (W.D. Wash.) (Whether Blue Cross organization is entitled to loss deductions for terminations of subscriber contracts held as of January 1, 1987, when it became taxable).
  • Pacific Life Ins Co v. United States, Docket No. 2:03-cv-04643-PJW (C.D. Cal. 2005) (Whether company entitled to deductions for increases in a premium stabilization reserve);
  • CUNA Mutual Ins Soc v. United States, No. 3:07-cv-00253-bbc (W.D. Wis.) (Treatment of 20 percent unearned premium reserve haircut transition rule);
  • Tennessee Rural Health Improvement Association v. United States, No. 1:03cv0015 (M.D. Tenn.) (Whether association qualifies as an exempt organization under I.R.C. § 501(c)(4) or as a fraternal benefit society exempt from tax under I.R.C. § 501(c)(8));
  • MBIA Inc. v. Commissioner, Docket No. 5429-99 (U.S. Tax Court) (Addressing disallowance of $22 million in deductions under I.R.C. § 265 and disallowance of deductions respecting reserve treatment of refunding credits; both issues fully conceded by IRS);
  • Reliance Standard Life Ins Co v. United States, Civil No. 98-3134 (E.D. Pa.) (Addressing whether taxpayer was entitled to carryovers respecting amortization of insurance contracts; settled with U.S. Department of Justice);
  • Federated Mutual Ins Co v. United States, Civil No. 98-CV-12910RHK/FLN (D. Minn.) (Addressing whether estimated salvage and subrogation should be taken into account in computing pre-1990 losses incurred under I.R.C. § 832(b)(5)(A)(iii), and addressing whether taxpayer is entitled to relief under § 11305(c)(2) of Pub. L. 101-508; settled with U.S. Department of Justice);
  • The St. Paul Companies, Inc. v. United States, No. 99-689 T (U.S. Court of Federal Claims) (Addressing the sufficiency of a claim for refund; fully conceded by U.S. Department of Justice);
  • Lone Star Life Ins Co v. Commissioner, Docket No. 14781-96 (U.S. Tax Court) (Settled with IRS);
  • Globe Life And Accident Ins Co v. United States, No. 03-5034 (U.S. Court of Appeals for the Federal Circuit) (Settled with U.S. Department of Justice on appeal from 54 Fed. C1. 132 (2002)) (Whether agency relationships may be valued and amortized);
  • Utica Mutual Ins Co v. Commissioner, Nos. 2402-01 and 2403-01 (U.S. Tax Court) (Whether the IRS has abused its discretion in changing the taxpayer’s method of accounting for determining discounted loss reserves); and
  • Transamerica Corp v. Commissioner, Nos. 8455-00 and 8456-00 (U.S. Tax Court) (Reserve and original issue discount issues) (Co-counsel).