Blue Cross & Blue Shield United v. United States

OPINION

HORN, Judge.

This tax case was brought by Blue Cross & Blue Shield United of Wisconsin (BCW), the common parent company of a group of affiliated taxable insurance and service corporations during the period at issue in this case. In a previous opinion, this court granted partial summary judgment for the government. See Blue Cross & Blue Shield United of Wis. & Subsidiaries v. United States (Blue Cross I), 56 Fed.Cl. 697 (2003). Following that decision, the parties entered into a stipulation for partial dismissal and for entry of judgment of the remaining issues in the case, those not the…