State Farm Mut. Auto. Ins. Co. v. Comm'r
United States Tax Court
P is an affiliated group of corporations filing a consolidated Federal income tax return. The group comprises both life and nonlife insurance companies, referred to as the life subgroup and the nonlife subgroup, respectively.
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P is an affiliated group of corporations filing a consolidated Federal income tax return. The group comprises both life and nonlife insurance companies, referred to as the life subgroup and the nonlife subgroup, respectively. P became subject to the alternative minimum tax (AMT) for 1987 as a result of events in 1989 generating a nonlife subgroup net operating loss carryback from 1989 to 1987. For purposes of determining its AMT liability, P calculated the book income adjustment on a consolidated basis. R maintains that the book income adjustment is to be made on a subgroup basis, with a…
1Opinion of the Court
OPINION
Cohen, Judge:
Respondent determined a Federal income tax deficiency in the amount of $1,235,690 with respect to the 1987 taxable year of State Farm Mutual Automobile Insurance Co. & Subsidiaries (herein collectively petitioner). By answer, respondent asserted an increased deficiency of $2,827,110. The principal issue for decision is the computation of petitioner’s alternative minimum tax (AMT) liability for 1987, which in turn will involve consideration of the amount of petitioner’s alternative tax net operating loss (ATNOL) carryback from 1989. Integral to each of these calculations is…
2Cases cited6 opinions
- United Dominion Industries, Inc. v. United StatesSupreme Court of the United States · 2001
- Allen v. Comm'rUnited States Tax Court · 2002
- Connecticut General Life Insurance Company v. Commissioner of Internal Revenue (Tax Court No. 92-21212). Cigna Corporation and Consolidated Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 92-21213)Court of Appeals for the Third Circuit · 1999
- George Nichols, Iii, in His Capacity as Liquidator of Kentucky Central Life Insurance Company v. United StatesCourt of Appeals for the Sixth Circuit · 2001
- Honeywell, Inc. v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- State Farm Mutual Automobile Insurance v. CommissionerCourt of Appeals for the Seventh Circuit · 2004
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2006
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2008
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2006
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2008
4 more not listed; retrieve them via the Exa API.