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WINN-DIXIE STORES, INC. v. C.I.R.

No. 00-11828.

254 F.3d 1313 (2001)

WINN-DIXIE STORES, INC. AND SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

Decided June 28, 2001.

Attorney(s) appearing for the Case

Jennifer K. Gray, Thomas P. Marinis, Vinson & Elkins, Houston, TX, Michael J. Henke, Tegan M. Flynn, Vinson & Elkins, Washington, DC, Thomas Crichton, IV, Vinson & Elkins, Dallas, TX, for Petitioner-Appellant.

Richard Farber, U.S. Dept. of Justice, Tax Div., Robert W. Metzler, U.S. Dept. of Justice, Tax Div., Appellate Sec., Washington, DC, for Respondent-Appellee.

Bernard J. Long, Jr., Dow, Lohnes & Albertson, PLLC, Washington, DC, for Harold G. Ingraham, Jr., Amicus Curiae.

Before WILSON and COX, Circuit Judges, and RYSKAMP, District Judge.

PER CURIAM:

Winn-Dixie Stores, Inc. appeals the tax court's judgment resting on the conclusion that Winn-Dixie was not entitled to deduct interest and fees incurred in borrowing against insurance policies that it owned on the lives of more than 36,000 Winn-Dixie employees. We affirm.

Background

In summary, the tax court found the following facts: In 1993, Winn-Dixie embarked on a broad-based company-owned life-insurance (COLI) program whose...

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