Connecticut General Life Insurance Company - Page 2

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                  A. Duane Webber, Leonard B. Terr, C. David Swenson, and                                
            Christopher R. Loomis, for petitioners.                                                      
                  John A. Guarnieri, Richard H. Gannon, and Richard L.                                   
            Osborne, for respondent.                                                                     

                                                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 operating losses of nonlife                            
            companies that may reduce income of life companies, companies                                
            that constituted members of a “recently acquired” affiliated                                 
            group of nonlife companies that previously filed consolidated                                
            Federal income tax returns are to be treated as a single                                     
            aggregate entity, as petitioners contend, or as separate                                     
            entities, as respondent contends.                                                            
                  The issue presented in these cross-motions for summary                                 
            judgment involves deficiencies determined by respondent in the                               
            Federal income taxes of petitioners Connecticut General Life                                 





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