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STATE FARM MUT. AUTO. INS. CO. v. C.I.R.

No. 11-3478.

698 F.3d 357 (2012)

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 31, 2012.

Attorney(s) appearing for the Case

Jerome B. Libin (argued), Attorney, Sutherland, Asbill & Brennan LLP, Washington, DC, for Petitioner.

Tamara W. Ashford , Jonathan S. Cohen , Robert W. Metzler , Attorneys, Department of Justice, Tax Division, CATEPS, Gilbert S. Rothenberg , Deputy Assistant Attorney General, Department of Justice, Office of the Attorney General, Francesca Ugolini Tamami (argued), Attorney, Department of Justice, Tax Division, CATEPS, Washington, DC, for Respondent-Appellee.

Constantine L. Trela, Jr. , Attorney, Sidley Austin LLP, Chicago, IL, for Amicus Curiae.

Before MANION, ROVNER, and HAMILTON, Circuit Judges.

HAMILTON, Circuit Judge.

This appeal presents two distinct questions regarding the taxation of insurance companies. State Farm Mutual Automobile Insurance Company has appealed from two rulings of the United States Tax Court that were part of the same case. One ruling concerns the tax treatment of bad-faith punitive damage awards that have not yet been paid. The other concerns the alternative minimum tax regime — a complicated area of the tax code that high...

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