Legal Opinion
American International Group, Inc. v. United States
United States Court of Federal Claims
Decided July 3, 1997No. Nos. 93-467T, 94-390TPublished
1Opinion of the Court
OPINION
BRUGGINK, Judge.
This is an action for refund of overpayment of taxes. It is brought by two holding companies that own corporations engaged primarily in the insurance and financial services business. The alleged overpayment resulted from the reduction by the Internal Revenue Service (IRS) of losses claimed by the plaintiffs. Trial was held in Washington, D.C. on April 9, 1997. For the reasons set out below, the court concludes that plaintiffs’ calculations of losses were correct.
BACKGROUND
The type of insurance involved in the transactions pertaining to this ease was mortgage guaranty…
2Cases cited6 opinions
- United States v. General Dynamics Corp.Supreme Court of the United States · 1987
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1992
- Hanover Insurance Company, Successor in Interest to Massachusetts Bonding and Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1979
- Maryland Savings-Share Insurance v. United StatesUnited States Court of Claims · 1981
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