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UNUM CORP. v. U.S.

Civil No. 93-369-P-C.

929 F.Supp. 15 (1996)

UNUM CORPORATION and Unum Life Insurance Company of America, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Maine.

May 23, 1996.

Attorney(s) appearing for the Case

William J. Kayatta Jr., Pierce, Atwood, Scribner, Allen, Smith & Lancaster, Portland, Maine, Barbara H. Furey, Barry W. Larman, Unum Life Insurance Company, Portland, Maine, for Plaintiffs.

David R. Collins, Asst. U.S. Atty., Office of the U.S. Attorney, Portland, Maine, Scott H. Harris, U.S. Department of Justice, Tax Division, Washington, D.C., for Government.

MEMORANDUM OF DECISION AND ORDER

GENE CARTER, Chief Judge.

Plaintiffs UNUM Corporation ("UNUM Corp.") and UNUM Life Insurance Company of America ("UNUM America") sue Defendant United States of America ("the Government" or "the IRS") seeking a tax deduction valued at approximately eighty million dollars. Plaintiffs claim that the cash and stock distributed to their policyholders pursuant to Plaintiffs' Plan of Recapitalization and Conversion, Stipulated...

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