Highmark, Inc. v. United States

OPINION

MARGOLIS, Senior Judge.

This tax refund case is before the Court on cross-motions for summary judgment. The parties presented their arguments in briefs and at a hearing on June 20, 2007. Plaintiff Highmark, Inc., which is the successor in interest to Pennsylvania Blue Shield and its subsidiaries, (“Highmark”) seeks at least $21,329,919, plus interest, from the defendant the United States, for alleged overpayment of federal income taxes for tax years 1991 through 1995. Specifically, Highmark claims deductions for losses from the termination and/or cancellation of health care coverage…