109 T.C. No. 5
UNITED STATES TAX COURT
CONNECTICUT GENERAL LIFE INSURANCE COMPANY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
CIGNA CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 21212-92, 21213-92. Filed August 12, 1997.
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.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011