In Ace Property & Casualty Insurance Co. v. Commissioner of Revenue, 473 Mass. 241 (2002), the Supreme Judicial Court held that the Federal Crop Insurance Act, 7 U.S.C. 1501 et seq., preempts state law and prohibits states from imposing any tax on or measured by premiums from crop insurance policies that are reinsured by the Federal Crop Insurance Corporation. The result of the decision is that the Department will not impose any tax on premiums related to policies that are reinsured by the Federal Crop Insurance Corporation.

/s/ Alan LeBovidge
Alan LeBovidge,
Commissioner of Revenue

ALL:DMS:dt
145918

November 27, 2002

TIR 02-24