State Farm Mutual Automobile Insurance v. Commissioner

*68ORDER

I

The Commissioner appeals the decision of the Tax Court granting State Farm a refund for overpayment in the amount of $56,900,746 for the 1987 tax year. The Tax Court held that, in computing State Farm’s tax liability for 1987, the alternative minimum tax (AMT) book income adjustment under former section 56(f) of the Internal Revenue Code, 26 U.S.C. § 56(f), is properly computed on a consolidated basis, with a single adjustment to be made for the entire State Farm affiliated group each year. The Commissioner argues that each State Farm subgroup must compute a book income adjustment. For…