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MINNESOTA LAWYERS MUT. INS. CO. v. C.I.R.

No. 01-1522.

285 F.3d 1086 (2002)

MINNESOTA LAWYERS MUTUAL INSURANCE COMPANY AND SUBSIDIARIES, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: April 15, 2002.

Attorney(s) appearing for the Case

Byron L. Frans, argued, Minneapolis, MN (John P. Borger, on the brief), for appellant.

Steven W. Parks, Tax Division, Dept. of Justice, argued, Washington, DC (David I. Pincus, on the brief), for appellee.

Before MURPHY, BEAM and BYE, Circuit Judges.

BYE, Circuit Judge.

The various state insurance regulatory bodies require insurers to have adequate "unpaid loss" reserves on hand to make future payments on claims that have been filed, but have not yet been paid. Insurance companies annually report the amount of their reserves to the state insurance regulators in an "annual statement" — a form prescribed by the National Association of Insurance Commissioners. The...

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