Georgia International Life Ins. Co. v. Commissioner
United States Tax Court
Petitioner, a life insurance company, sustained losses from operations for taxable years 1959 through 1965; it realized gains from operations for taxable years 1966 through 1971. On its Federal income tax return for taxable year 1970, petitioner reported long-term capital gains of $ 35,201,814.50, taxable investment income of $ 35,264,910.10, and gain from operations of $ 32,132,285.62, and it claimed $ 2,874,842.36 as its previously unused cumulative operations loss…
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Petitioner, a life insurance company, sustained losses from operations for taxable years 1959 through 1965; it realized gains from operations for taxable years 1966 through 1971. On its Federal income tax return for taxable year 1970, petitioner reported long-term capital gains of $ 35,201,814.50, taxable investment income of $ 35,264,910.10, and gain from operations of $ 32,132,285.62, and it claimed $ 2,874,842.36 as its previously unused cumulative operations loss deduction carryforward. Petitioner utilized the alternative tax method to calculate the tax on its life insurance company…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioner’s income tax for calendar year 1971 in the amount of $691,729.61. The issue for decision is whether petitioner is entitled to carry over to 1971 any portion of its operations losses from 1963 and 1964, which is contingent upon whether the operations loss carryforward was absorbed entirely by petitioner’s 1970 life insurance company taxable income. Resolution of the issue depends on whether petitioner’s operating loss carryover reduced both ordinary and capital gain sources of its life insurance company taxable income when it…
2Cases cited6 opinions
- United States v. Foster Lumber Co.Supreme Court of the United States · 1976
- Chartier Real Estate Co. v. CommissionerUnited States Tax Court · 1969
- Chartier Real Estate Company, Inc. v. Commissioner of Internal Revenue, (Three Cases)Court of Appeals for the First Circuit · 1970
- Olympic Foundry Company, a Washington Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1974
- Mutual Assurance Society of Virginia Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1974
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3Cited by1 opinion
- Georgia International Life Ins. Co. v. CommissionerUnited States Tax Court · 1983