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AMERICAN ELEC. POWER CO., INC. v. U.S.

No. 01-3495.

326 F.3d 737 (2003)

AMERICAN ELECTRIC POWER COMPANY, INC. et al., Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: April 28, 2003.

Attorney(s) appearing for the Case

Randolph Carson Wiseman (briefed), Bricker & Eckler, Columbus, OH, Richard E. May, Hunton & Williams, Washington, DC, James P. Holden (briefed), Susan H. Serling (briefed), Arthur L. Bailey (argued and briefed), Jean Male Baxley (briefed), Steptoe & Johnson, Washington, DC, for Plaintiffs-Appellants.

Dennis M. Donohue (argued and briefed), Richard Farber (briefed), United States Department of Justice, Appellate Section Tax Division, Washington, DC, James D. Hill (briefed), Internal Revenue Service, Office of Chief Counsel, Cincinnati, OH, Alex E. Sadler (briefed), United States Department of Justice, Tax Division, Washington, DC, for Defendant-Appellee.

Bernard J. Long (briefed), Dow, Lohnes & Albertson, Washington, DC, Raj Madan (briefed), Richard C. Stark (briefed), Sheri A. Dillon, John B. Magee (briefed), Gerald Goldman (briefed), McKee Nelson LLP, Washington, DC, for Amici Curiae.

Before NELSON, COLE, and GILMAN, Circuit Judges.

GILMAN, J., delivered the opinion of the court, in which COLE, J., joined. DAVID A. NELSON, J. (pp. 745-747), delivered a separate concurring opinion.

OPINION

GILMAN, Circuit Judge.

American Electric Power Company, Inc. (AEP) implemented a corporate-owned life insurance (COLI) plan in 1990 that caused it to purchase policies on the lives of over 20,000 of its employees. In 1996, AEP deducted from its federal income tax approximately $66 million in...

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