Legal Opinion

Trigon Insurance v. United States

District Court, E.D. Virginia

Decided December 17, 2002No. CIV. 3:00CV365PublishedCited by 7 opinions

1Opinion of the Court

MEMORANDUM OPINION

PAYNE, District Judge.

In this action, Plaintiff, Trigon Insurance Company (“Trigon”), seeks a refund of federal income taxes, plus interest, that it allegedly overpaid in the years 1989 through 1995. As explained fully in the Memorandum Opinion issued on August 9, 2002 (the “August 9 Opinion”), 1 Trigon and the United States disagreed over the meaning and effect of certain provisions of the Tax Reform Act of 1986 (the “1986 Act”). 2 Trigon asserted that certain contracts it had entered into with individual subscribers and health care providers before 1987 were valuable…

2Cases cited28 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. United States v. JanisSupreme Court of the United States · 1976
  3. Helvering v. TaylorSupreme Court of the United States · 1935
  4. Vanicek v. CommissionerUnited States Tax Court · 1985
  5. Hutchinson v. StatonCourt of Appeals for the Fourth Circuit · 1993

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3Cited by7 opinions

  1. Washington Mutual, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 2017
  2. Wmi Holdings Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2018
  3. Capital Blue Cross & Subsidiaries v. Comm'rUnited States Tax Court · 2004
  4. Washington Mutual, Inc. v. United StatesDistrict Court, W.D. Washington · 2014
  5. Capital Blue Cross & Subsidiaries v. Comm'rUnited States Tax Court · 2004

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