This article discusses Miller & Chevalier's representation of Swiss insurance company Starr International Co. Inc. (SICO), which is fighting for a $38 million tax refund from the Internal Revenue Service (IRS). This is a case of first impression. DC District Court Judge Casey Cooper has ruled that the court will determine if the IRS ("Competent Authority") abused its discretion. The Department of Justice is attempting for the second time to dismiss SICO's lawsuit merely by repeating arguments the DC district court has already rejected. Starr is represented by Miller & Chevalier Members Kevin M. Downing*, Thomas E. Zehnle*, Andrew T. Wise, and Marc J. Gerson.

*Former Miller & Chevalier attorney