In self-procurement tax case Dow Chem. v. Rylander,
38 S.W.3d 741 (Tex. App. Austin 2001), Dow Chemical won, but the case only applied to narrow facts and circumstances. State Bd. of Ins. v. Todd Shipyards,
370 U.S. 451 (1962), was the case cited. It could have been a prelude to captive owners resisting demands by states, but it didn't pan out that way. It is still a powerful argument for non-admitted coverage avoiding self-procurement taxes, but rarely invoked by timid captive tax advisers.