Capital Blue Cross & Subsidiaries v. Comm'r
United States Tax Court
As part of its statutory conversion under sec. 1012(a) and (b) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2390, from a tax-exempt to a taxable entity, petitioner generally was entitled to step up its tax basis in its assets to their Jan. 1, 1987, fair market value. Held, among other things, for 1994: (1) The basis step-up provision of sec. 1012(c)(3)(A)(ii) of the Tax Reform Act of 1986, Pub.
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As part of its statutory conversion under sec. 1012(a) and (b) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2390, from a tax-exempt to a taxable entity, petitioner generally was entitled to step up its tax basis in its assets to their Jan. 1, 1987, fair market value. Held, among other things, for 1994: (1) The basis step-up provision of sec. 1012(c)(3)(A)(ii) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2394, is not limited to "sale or exchange" transactions; and (2) because petitioner's valuation of its health insurance group contracts did not constitute a…
1Opinion of the Court
OPINION
SWIFT, Judge:
For 1994, respondent determined a deficiency of $532,192 in petitioner’s Federal income tax.
The issue for decision involves the allowability of $3,973,023 (hereinafter rounded to $4 million) in cumulative total loss deductions claimed under section 165 relating to petitioner’s health insurance group contracts (group contracts).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1994, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner, Capital Blue Cross, is the common parent of an affiliated…
2Cases cited35 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Green v. Bock Laundry MacHine Co.Supreme Court of the United States · 1989
- Idahoan Fresh v. Advantage ProduceCourt of Appeals for the Third Circuit · 1998
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