BLUE CROSS & BLUE SHIELD, INC. v. COMMISSIONER

Docket No. 361-98.

115 T.C. 148 (2000)

BLUE CROSS & BLUE SHIELD OF TEXAS, INC., AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 18, 2000.


Attorney(s) appearing for the Case

Richard Bromley, Glen H. Kanwit, R. Lee Christie, and Tracy D. Williams, for petitioner.

John S. Repsis, Charles W. Maurer, Jr., Stephanie R. Jensen, and Michael C. Prindible, for respondent.


OPINION

SWIFT, Judge.

For 1992 and 1993, respectively, respondent determined deficiencies of $3,094,736 and $2,184,916 in petitioner's Federal income taxes.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After settlement of some issues, the issue...

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