Hoosier Energy Rural Electric Cooperative, Inc. v. John Hancock Life Insurance
Court of Appeals for the Seventh Circuit
1Opinion of the Court
EASTERBROOK, Chief Judge.
Hoosier Energy, a co-op, had depreciation deductions that it could not use. John Hancock Life Insurance Co. had income exceeding its available deductions. The two engaged in a transaction designed to move Hoosier Energy’s deductions to John Hancock. They entered into a leveraged lease: John Hancock paid Hoosier Energy $300 million for a 63-year lease of an undivided 2/3 interest in Hoosier Energy’s Merom generation plant. Hoosier Energy agreed to lease the plant back from John Hancock for 30 years, making periodic payments with a present value of $279 million. The $21…
2Cases cited15 opinions
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