Perspective on Reserve Mechanical Corp. v. Commissioner of Internal Revenue

Reserve Mechanical Corp. f.k.a. Reserve Casualty Corp. v. Commissioner of Internal Revenue (“Reserve”) was decided by the United States Tax Court in an opinion issued by Judge Kathleen Kerrigan (the “Opinion”) on June 18, 2018. Any analysis of the Opinion must be done with reference to the trial record. Because a court’s written opinion sometimes – as we believe is the case here – may not fully reflect the evidence before it, it is important to review the record when performing a proper review of a court decision.

Opinion and trial transcript

Capstone offers the following series of commentaries on the tax court’s decision in Reserve:

June 19, 2018Initial Statement

June 27, 2018Commentary on Insurable Risks

July 9, 2018 - Commentary on Policy Pricing