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Winn-Dixie Stores Inc. v. Comm'r., 113 T.C. No. 21 (October 19, 1999)

This transaction involved the purchase of a company-wide corporate-owned life insurance ("COLI") group plan, the consequences of which have changes since the enactment of the Health Insurance and Accountability Act of 1996.

The taxpayer deducted over $3.7 million in accrued interest on policy loans and $100,00 in administrative fees related to the COLI policies.

The court concluded that the transaction was a sham and upheld the Service's disallowance of both deductions.

Source: Alice G. Abreu* ``Selected Highlights: Federal Corporate Taxation May 1, 1999 to May 1, 2000" Penn State 54th Annual Tax Conference (May 22, 2000).

* Professor of Law, Temple University of Law, Philadelphia PA 19122

Steven Huddart
Smeal College of Business, Penn State University, University Park, PA 16802-3603 USA
(814) 863-0048
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