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Insurance Co. (ConnLife) and CIGNA Corp. and their consolidated
subsidiaries (CIGNA) as follows:
Petitioner Year Deficiency
ConnLife 1980 $ 3,360,873
CIGNA 1982 15,080,878
CIGNA 1983 1,916,121
CIGNA 1984 41,066,157
CIGNA 1985 752,636
Total $62,176,665
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
For 1981 and through March 31, 1982, Connecticut General
Corp. (CG), ConnLife, and CG's over 40 affiliates (the CG Group)
joined in filing consolidated Federal income tax returns, with CG
as the common parent of the affiliated group. ConnLife
constituted the sole life insurance company in the CG Group.
Members of the CG Group were engaged primarily in selling,
underwriting, and servicing various types of insurance (namely,
individual and group life, health and annuity insurance, and
personal and commercial property and casualty (P&C) insurance).
Acquisition of INA
On March 31, 1982, the CG Group and INA Corp. (INA) and its
over 160 affiliated companies (the INA Group) combined for
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