State Farm Mut. Auto. Ins. Co. v. Comm'r
United States Tax Court
P was the common parent of a life-nonlife consolidated group from 1996 through 2002. When making its alternative minimum tax (AMT) calculations for those years, it originally calculated its adjusted current earnings (ACE) adjustment separately for its life and nonlife subgroups. After R issued P a notice of deficiency for 1996 through 1999, P recalculated its AMT using a revised methodology.
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P was the common parent of a life-nonlife consolidated group from 1996 through 2002. When making its alternative minimum tax (AMT) calculations for those years, it originally calculated its adjusted current earnings (ACE) adjustment separately for its life and nonlife subgroups. After R issued P a notice of deficiency for 1996 through 1999, P recalculated its AMT using a revised methodology. P's revised methodology calculates ACE on a consolidated basis and does not apply the loss limitation rules of sec. 1503(c), I.R.C., to preadjustment alternative minimum taxable income (AMTI) for purposes…
1Opinion of the Court
OPINION
Goeke, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes of $12,830,522, $55,903,247, $25,981,117, and $14,249,973 for 1996, 1997, 1998, and 1999, respectively. Petitioner disputes $13,625 of the deficiency for 1996 and the entire deficiency for each of 1997, 1998, and 1999. Petitioner claims overpayments of $156,917,448, $214,471,611, and $138,570,516 for 1997, 1998, and 1999, respectively.
Petitioner raised seven issues in its petition, five of which have been settled. Of the two remaining issues this Opinion addresses solely the calculation of petitioner’s…
2Cases cited12 opinions
- Atlantic Cleaners & Dyers, Inc. v. United StatesSupreme Court of the United States · 1932
- Snap-Drape, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1996
- Estate of Gerald L. Wallace, Deceased, Celia A. Wallace, and Celia A. Wallace v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1992
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- 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
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3Cited by4 opinions
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- State Farm Mutual Automobile Insurance Co. & Subsidiaries v. CommissionerUnited States Tax Court · 2010
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2008
- State Farm Mutual Automobile Insurance Company & Subsidiaries v. CommissionerUnited States Tax Court · 2008