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PROGRESSIVE CORP. AND SUBSIDIARIES v. U.S.

No. 91-3578.

970 F.2d 188 (1992)

The PROGRESSIVE CORPORATION AND SUBSIDIARIES, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided July 22, 1992.

Rehearing Denied August 25, 1992.

Attorney(s) appearing for the Case

Richard Katcher (argued and briefed), Peter W. Vogt, Alexander J. Szilvas, Baker & Hostetler, Cleveland, Ohio, for plaintiff-appellee.

Daniel M. Houlf, Trial Atty., U.S. Dept. of Justice, Tax Div., Washington, D.C., Annette G. Butler, Asst. U.S. Atty., Cleveland, Ohio, Gary R. Allen, Acting Chief (briefed), Kenneth L. Greene, Charles Bricken (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for defendant-appellant.

Before: MILBURN and NORRIS, Circuit Judges; and ENGEL, Senior Circuit Judge.

MILBURN, Circuit Judge.

Defendant United States of America appeals from the summary judgment granted by the district court in favor of plaintiff, The Progressive Corporation and Subsidiaries ("Progressive"), which awarded Progressive a tax refund of $2,191,595 plus interest from the date the taxes were paid. On appeal, the principal issues are (1) whether Progressive's simultaneous purchases of a stock and a put option on the same stock resulted in a holding period...

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