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WELLPOINT, INC. v. C.I.R.

No. 09-3163.

599 F.3d 641 (2010)

WELLPOINT, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 23, 2010.

Attorney(s) appearing for the Case

Philip C. Cook, Attorney (argued), Alston & Bird, Atlanta, GA, for Petitioner-Appellant.

Arthur T. Catterall, Attorney (argued), Department of Justice, Washington, DC, for Respondent-Appellee.

Before POSNER, ROVNER, and SYKES, Circuit Judges.

POSNER, Circuit Judge.

The petitioner, WellPoint (successor to Anthem, Inc.), is a for-profit seller of health insurance policies through subsidiaries that include a number of Blue Cross Blue Shield insurance companies (licensees of the Blue Cross and Blue Shield Association). In the 1990s, the petitioner, when it was still Anthem, acquired three such companies, one each in Connecticut, Kentucky, and Ohio. Both the acquiring...

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