Connecticut Gen. Life Ins. Co. v. Commissioner
United States Tax Court
Held: In consolidating nonlife insurance companies with life insurance companies and for purposes of calculating the amount of net operating losses of nonlife insurance companies that, under sec. 1503(c)(1) and ( 2), I.R.C., may reduce income of the life insurance companies, companies that constituted members of a "recently acquired" affiliated group of nonlife insurance companies that previously filed consolidated Federal income tax returns are to be treated as separate…
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Held: In consolidating nonlife insurance companies with life insurance companies and for purposes of calculating the amount of net operating losses of nonlife insurance companies that, under sec. 1503(c)(1) and ( 2), I.R.C., may reduce income of the life insurance companies, companies that constituted members of a "recently acquired" affiliated group of nonlife insurance companies that previously filed consolidated Federal income tax returns are to be treated as separate entities.
1Opinion of the Court
OPINION
Swift, Judge:
These consolidated cases are before the Court under Rule 121 on the parties’ cross-motions for summary judgment. Petitioners contend that if their motion for summary judgment is not granted, a certain factual matter remains in dispute that precludes summary judgment in favor of respondent.
The issue for decision is whether, in consolidating nonlife insurance companies (sometimes referred to as nonlife companies) with life insurance companies (sometimes referred to as life companies) and for purposes of calculating, under section 1503(c)(1) and (2), the amount of net…
2Cases cited8 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Armco, Inc. v. CommissionerUnited States Tax Court · 1986
- Alexander v. Comm'rUnited States Tax Court · 1990
3 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- 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
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2002
- American Air Liquide, Inc. v. CommissionerUnited States Tax Court · 2001
- 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 · 2008
10 more not listed; retrieve them via the Exa API.