PER CURIAM:
This appeal arises out of an insurance policy that The Upper Deck Corporation ("Upper Deck"), purchased from American International Specialty Lines Insurance Company ("AISLIC"). The policy insured a tax strategy that KPMG, an accounting firm, developed for Upper Deck. The IRS investigated the tax strategy and determined that it constituted an improper tax shelter. Upper Deck then settled with the IRS for $80 million in back taxes and interest, and with...
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