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
Georgia International Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Georgia International Life Ins. Co. v. Commissioner
Docket No. 7633-80
United States Tax Court
81 T.C. 166; 1983 U.S. Tax Ct. LEXIS 50; 81 T.C. No. 15;
August 29, 1983, Filed
Decision will be entered for the respondent.
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…
2Cases cited7 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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