COMPTROLLER OF THE TREASURY v. LEADVILLE INSURANCE COMPANY

Tax regulation — Exemption — Non-insurance-related revenue

Following an audit of Macy’s Retail Holding, Inc. (“MRHI”), the Comptroller of the Treasury (“Appellant”) assessed $23,831,054.34 in taxes, penalties, and curiosity from Leadville Insurance Company (“Appellee”), an entirely owned subsidiary of Macy’s, Inc. (“Macy’s”), the guardian firm for the Macy’s franchise, through the 1996-2003 tax years. Appellant’s evaluation was upheld by the Comptroller’s Hearings and Appeals Section and the Tax Court.

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