United States Seventh Circuit

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WellPoint, Inc. v. Comm'r of Internal Revenue, 09-3163

Judgment of the Tax Court that plaintiff could not deduct from its taxable income either the amount it paid to the states or the legal expenses that it had incurred in the litigation, involving the acquisition of Blue Cross Blue Shield insurance companies, is affirmed as, under the application of the "origin of the claim" doctrine, costs incurred in defending the lawsuit were capital expenditures and so could not be deducted as ordinary and necessary business expenses.

Appellate Information

  • Decided 03/23/2010
  • Published 03/23/2010



  • United States Seventh Circuit