State of Nevada, Department of Insurance v. Humana Health Insurance of Nevada, Inc.

*357OPINION

Humana Health Insurance of Nevada, Inc. (Humana-Nevada) filed tax returns for the 1988, 1989, and 1990 tax years. The returns claimed the home office tax credit allowed to insurers under NRS 680B.050. After disallowing as untimely Humana-Nevada’s 1988 request for the credit, the Department of Insurance (DOI) commenced an examination of insurers claiming the home office tax credit, including Humana-Nevada. The DOI determined Humana-Nevada did not function as a home office and ordered Humana-Nevada to pay the delinquent amount of taxes it had claimed in the credit for the 1989 and 1990…