Selected Federal Tax Cases Litigated to Decision
- Tyson Foods, Inc. v. Commissioner, T.C. Memo 2007-188 (the primary issue was the manner in which the taxpayer allocated costs to ending inventory).
- Bank One Corp. v. Commissioner, 120 T.C. 174 (2003), aff’d in part, vacated and remanded in part, JP Morgan Chase v. Commissioner, 458 F.3d 564 (7th Cir. 2006), aff’d 530 F.3d 634 (7th Cir. 2008) (method of accounting for swaps).
- PDV America, Inc. v. Commissioner, T.C. Memo 2004-118 (depreciation of above ground storage tanks).
- Atchison, Topeka and Santa Fe Railway Co. v. United States, 61 Fed. Cl. 501 (2004) (Railroad Retirement Tax Act refund claim).
- Physicians Insurance Co. of Wisconsin v. Commissioner, T.C. Memo 2001-304 (medical malpractice loss reserves).
- Best Life Assurance Co. v. Commissioner, T.C. Memo 2000-134, aff’d 281 F.3d 828 (9th Cir. 2002) (accident and health loss reserves).
- Central Reserve Life Corp. v. Commissioner, 113 T.C. 231 (1999) (accident and health loss reserves).
- Sprint Corp. v. Commissioner, 108 T.C. 384 (1997) (investment credit and depreciation).
Selected Pending Federal Tax Cases
- First Data Corp. v. Commissioner, Docket No. 7042-09 (Tax Court).
- ABA Retirement Funds v. United States, Docket No. 09-CV-6993 (N.D. Ill).
- Principal Life Insurance Company v. United States, Docket No. 1:07-cv-00006-FMA (Court of Federal Claims).
- Principal Investors Corp. v. United States, Docket No. 11-610T-FMA (Court of Federal Claims).
- Glacier Mountain, L.P. v. United States, Docket No. 12-582T-FMA (Court of Federal Claims).
- Brinks, Hofer, Gilson & Lione v. Commissioner, Docket No. 014414-13 (Tax Court).
Selected Federal Tax Cases Not Litigated to Decision
- Don & Jean Tyson v. Commissioner, Docket No. 19663-03 (Tax Court, settled).
- Tyson Foods, Inc. v. Commissioner, Docket No. 2263-07 (Tax Court, settled).
- Wolters Kluwer North America, Inc. v. Commissioner, Docket No. 27900-07 (Tax Court research credit case, settled).
- Howard McKee v. United States, Docket No. 1:07-CV-236 (Court of Federal Claims, settled).
Pre-Litigation Settlement of US$100+ Million Federal Tax Issues Resolved at Minimum of 72% Government Concession
- Financial product/tax shelter transaction entered into by broker/dealer.
- Deferred compensation arrangement of hedge fund manager.
- Deductibility of interest on financial product issued by publicly traded company.
- Charitable donation of real property by publicly traded company.
- Repair/expense issue of publicly traded company.
- Variable pre-paid forward contracts of publicly traded company.
- Deductibility of premiums paid to Bermuda captive insurance company.