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STATE FARM MUT. AUTO. INS. CO. & SUBS. v. COMMR.

Docket No. 5426-05.

130 T.C. 263 (2008)

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY & SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 23, 2008.

Attorney(s) appearing for the Case

Jerome B. Libin, James V. Heffernan, Mary E. Monahan, and Jeffrey N. Starkey, for petitioner.

Alan M. Jacobson, Jan E. Lamartine, and William F. Barry, IV, for respondent.

OPINION

GOEKE, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes of $12,830,522, $55,903,247, $25,981,117, and $14,249,973 for 1996, 1997, 1998, and 1999, respectively. Petitioner disputes $13,625 of the deficiency for 1996 and the entire deficiency for each of 1997, 1998, and 1999. Petitioner claims overpayments of $156,917,448, $214,471,611, and $138,570,516 for 1997, 1998, and 1999, respectively.

Petitioner...

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