State Farm Mutual Automobile Insurance v. Commissioner

HAMILTON, Circuit Judge.

This appeal presents two distinct questions regarding the taxation of insurance companies. State Farm Mutual Automobile Insurance Company has appealed from two rulings of the United States Tax Court that were part of the same case. One ruling concerns the tax treatment of bad-faith punitive damage awards that have not yet been paid. The other concerns the alternative minimum tax regime — a complicated area of the tax code that high-earning individuals and corporations must contend with, made even more complicated here by the special rules applicable to life insurance…