Illinois Lumber & Material Dealers Ass'n Health Insurance Trust v. United States

LOKEN, Circuit Judge.

Illinois Lumber and Material Dealers Association Health Insurance Trust (“Illinois Lumber”) is a tax-exempt insurance trust operating under 26 U.S.C. (I.R.C.) § 501(c)(9). Illinois Lumber purchased life insurance policies issued by General American Mutual Holding Company (“GAMHC”), a mutual insurance company. In 2003, GAMHC began the process of demutualization, converting from an insurer owned by its policyholder members to one owned by stockholders. See generally Dorrance v. United States, 877 F.Supp.2d 827, 829-30 (D.Ariz.2012). 1 In September 2003, Illinois Lumber…