United States Fifth Circuit
BLUE CROSS & BLUE SHIELD OF TEXAS, INC. v. COMM'R OF INTERNAL REVENUE, 02-60188
Amounts referred to as "coordination of benefits savings" did not qualify as "estimated salvage recoverable" that would enable a health insurance provider to claim a special tax reduction, and the provider did not qualify for protection under a Treasury Regulation 1.832-4(f)(2) safe harbor provision.
Appellate Information
- Decided 04/16/2003
- Published 04/17/2003
Judges
- FALLON, District Judge:, Before DeMOSS and STEWART, Circuit Judges, and FALLON, District Judge.
Court
- United States Fifth Circuit
Counsel
- For Appellant:
- Richard Bromley,R. Lee Christie, Glen H. Kanwit (argued), Tracy D. Williams, Belinda S. Morgan, Foley & Lardner, Chicago, IL, for Petitioner-Appellant., Frederick Hampden Robinson, Miller & Chevalier, Washington, DC, for Blue Cross and Blue Shield Ass'n, Amicus Curiae.
- For Appellees:
- Robert W. Metzler (argued), David I. Pincus, U.S. Dept. of Justice, Tax Div., Charles Casazza, Clerk, U.S. Tax Court, B. John Williams, Jr., IRS, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for Respondent-Appellee.