Blue Cross & Blue Shield United of Wisconsin & Subsidiaries 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 corpora*698tions during the period at issue in this case.1 The present cross-motions for partial summary judgment2 concern the calculation of BCW’s Internal Revenue Code (IRC) section 832(c)(4) losses incurred deduction for tax year 1987. See 26 U.S.C. § 832(c)(4) (1982 & Supp. V 1987) (hereinafter IRC § 832(c)(4)). As delineated in IRC § 832(b)(5), in order to calculate its IRC § 832(c)(4) losses incurred deduction,…