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United States Court of Appeals
Fifth Circuit
F I L E D
September 13, 2006
Charles R. Fulbruge III
Clerk
IN THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT
No. 05-51619
TEXAS MEDICAL ASSOCIATION INSURANCE TRUST,
Plaintiff-Appellant,
versus
UNITED STATES OF AMERICA,
Defendant-Appellee.
Appeal from the United States District Court for
the Western District of Texas
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Before JONES, Chief Judge, REAVLEY and PRADO, Circuit Judges.
PER CURIAM:
Taxpayer Texas Medical Association Insurance Trust appeals the district court’s
summary judgment dismissal of its claim for refund based on the deductibility of
premium expenses against proceeds from the sale of stock it received as the result of the
demutualization of the Prudential insurance company, pursuant to 26 U.S.C. § 277(a).
For the reasons stated in the district court’s opinion, Texas Med. Ass’n Ins. Trust v.
United States, 391 F. Supp. 2d 529 (W.D. Tex. 2005), the judgment is affirmed.
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AFFIRMED.
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