Legal Opinion

State Farm Mutual Automobile Insurance Company & Subsidiaries v. Commissioner

United States Tax Court

Decided June 23, 2008No. 5426-05Unknown

1Opinion of the Court

130 T.C. No. 16

UNITED STATES TAX COURT STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5426-05. Filed June 23, 2008. 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.…

2Cases cited13 opinions

  1. Atlantic Cleaners & Dyers, Inc. v. United StatesSupreme Court of the United States · 1932
  2. Snap-Drape, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1996
  3. 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
  4. Estate of Wallace v. CommissionerUnited States Tax Court · 1990
  5. 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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