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

Docket No. 5426-05.

135 T.C. 543 (2010)

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

United States Tax Court.

Filed November 8, 2010.

Attorney(s) appearing for the Case

Jerome B. Libin ,, James V. Heffernan , Mary E. Monahan , and Troy L. Olsen , for petitioner.

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

OPINION

GOEKE, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable years 1996 through 1999. Petitioner raised seven issues in its petition, six of which have been resolved. This Opinion addresses solely whether punitive damages and related costs of $202 million are includable in losses incurred under section 832(b)(5)1 for taxable years 2001 and 2002. For the reasons stated herein, we find...

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