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TRIGON INS. CO. v. U.S.

No. 3:00cv365.

215 F.Supp.2d 687 (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.

August 9, 2002.

Attorney(s) appearing for the Case

Gilbert E. Schill, McGuireWoods, LLP, Richmond, VA, James D. Bridgeman, McKee, Nelson, Ernst & Young, LLP, Washington, D.C., for Plaintiff.

Debra J. Prillaman, M. Hannah Lauck, United States Attorney's Office, Richmond, VA, Angelo Frattarelli, C. Paul Hurley, United States Department of Justice, Tax Division, Washington, D.C., Carolyn V. Grady, Epperly, Follis & Schork, P.C., Richmond, VA, for Defendant.

Stephen W. Miller, United States Attorney's Office, Richmond, VA, for Government.

MEMORANDUM OPINION

PAYNE, District Judge.

Plaintiff, Trigon Insurance Company ("Trigon"), formerly known as Blue Cross and Blue Shield of Virginia, filed this action to recover federal income taxes, plus interest, alleged to have been erroneously overpaid in the years 1989 through 1995. The United States opposes the refund on several grounds.

The dispute between the parties is over the meaning...

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