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TRIGON INS. CO. v. U.S.

No. CIV. 3:00CV365.

234 F.Supp.2d 581 (2002)

TRIGON INSURANCE COMPANY (Formerly Blue Cross and Blue Shield of Virginia), Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Virginia, Richmond Division.

December 17, 2002.

Attorney(s) appearing for the Case

Gilbert E. Schill, Jr., Esquire, McGuire-Woods LLP, Richmond, VA, James D. Bridgeman, Esquire, David J. Curtin, Esquire, Michael J. Desmond, Esquire, McKee Nelson, Washington, DC, for Plaintiff.

M. Hannah Lauck, Esquire, Assistant United States Attorney, United States Attorney's Office, Richmond, VA, Charles P. Hurley, Esquire, Trial Attorney, Tax Division, U.S. Department of Justice, Washington, DC, for Defendant.

MEMORANDUM OPINION

PAYNE, District Judge.

In this action, Plaintiff, Trigon Insurance Company ("Trigon"), seeks a refund of federal income taxes, plus interest, that it allegedly overpaid in the years 1989 through 1995. As explained fully in the Memorandum Opinion issued on August 9, 2002 (the "August 9 Opinion"),1 Trigon and the United States disagreed over the meaning and effect...

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