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STEARNS-ROGER CORP., INC. v. UNITED STATES

Civ. A. No. 81-C-2046.

577 F.Supp. 833 (1984)

STEARNS-ROGER CORP., INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Colorado.

January 10, 1984.

Attorney(s) appearing for the Case

Robert E. Benson, Holland & Hart, Denver, Colo., for plaintiff.

Robert N. Miller, U.S. Atty., Denver, Colo., Robert Horwitz, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., for defendant.

AMENDED MEMORANDUM OPINION AND ORDER

CARRIGAN, District Judge.

In November 1974, the plaintiff, Stearns-Roger Corporation (Stearns-Roger), incorporated a captive insurance company, Glendale Insurance Company (Glendale). For the tax years 1974 through 1978, Stearns-Roger deducted, as business expenses for federal income tax purposes, $6,042,515.80 in insurance premiums it paid to Glendale. The Internal Revenue Service (IRS) subsequently audited Stearns-Roger...

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