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United States v. General Dynamics
Citation:
481 U.S. 239 (1987)Facts
General Dynamics Corporation, a defense contractor, maintained a self-insurance plan for its employees’ medical care. Under this plan, employees submitted claims for medical services to private insurance carriers who processed the claims and forwarded them to General Dynamics for payment. For tax years 1972 and 1973, General Dynamics deducted not only claims that had been submitted but also estimates for claims that had been incurred by employees who had received medical treatment but had not yet submitted claims (IBNR claims). The IRS disallowed these deductions, asserting that the “all events test” had not been satisfied because the filing of a claim was a condition precedent to liability. General Dynamics paid the assessed tax deficiencies and sued for a refund.
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