Residual Value Insurance Scores Big Win In U.S. Tax Court

"Is it live, or is it Memorex?", the commercial used to say in the days of cassette tapes and reel-to-reel recorders, long before digital recording entered our lexicon. We here consider an Opinion from the U.S. Tax Court where a taxpayer has taken the position that a certain type of insurance it sells is insurance for tax purposes (the real deal), but the Service contends that it is not really insurance but more in the way of a financial hedging contract.