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.


Visit for opinion and trial transcripts.


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

May 15th, 2019 - Commentary #5 on Syzygy and the Tax Court’s Continued Application of Erroneous Legal Analysis to Pooling Arrangements 

January 4, 2019 - Commentary #4 on The Tax Court’s Erroneous Application of Avrahami to Reserve

December 19, 2018 - Commentary #3 on Policy Selection 

July 9, 2018 - Commentary #2 on Policy Pricing

June 27, 2018Commentary #1 on Insurable Risks

June 19, 2018Initial Statement