State Farm Mutual Insurance Co., et al. v. Comr., 135 T.C. 543 (2010)

(insurance company could not  treat a $9 million punitive damage judgment as an I.R.C. Sec. 832(b)(5) loss; had company been able to do so, company could have increased its loss reserves by the same amount; judgment held to be "extra-contractual" (thus, deductible as a business loss)because it was not covered by a liability policy, but was the result of the petitioner's own misconduct).