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.
Visit www.reserve-casualty-corp.com for opinion and trial transcripts.
Capstone offers the following series of commentaries on the tax court’s decision in Reserve:
February 28, 2020 - Reserve Files Opening Brief with Tenth Circuit Court of Appeals
December 19, 2018 - Commentary #3 on Policy Selection
July 9, 2018 - Commentary #2 on Policy Pricing
June 27, 2018 – Commentary #1 on Insurable Risks
June 19, 2018 – Initial Statement
THIRD-PARTY RESERVE ARTICLES
March 2, 2020 - Captive Review: Appeal Filed in Reserve Tax Court Case
March 2, 2020 - Business Insurance: Captive associations fight 831(b) ruling
February 28, 2020 - Tax Notes - IRS Microcaptive Victory Hinged on Faulty Analysis Company Says