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only life insurance company in the CIGNA Group, earned the
following income:
CNOL’s of Nonlife Income
Year Companies of ConnLife
1982 ($ 197,385,675) $116,294,363
1983 ( 244,963,449) 82,316,221
1984 ( 553,077,555) 331,452,903
1985 ( 1,229,220,860) 274,458,803
The above CNOL’s of the nonlife companies consisted of
CNOL’s of both eligible companies under section 1503(c)(2)
(namely, nonlife companies that had been members of the prior CG
Group and the CIGNA Group for at least 5 years) and ineligible
companies under section 1503(c)(2) (namely, nonlife companies
that had not been members of the prior CG Group and the CIGNA
Group for at least 5 years). Because they had not been members
of the prior CG Group and the CIGNA Group for at least 5 years,
all of the companies that constituted members of the former INA
and PHC Groups constituted ineligible nonlife companies.
On the consolidated Federal income tax returns for 1982
through 1985 -- in order to calculate the amount of net operating
losses (NOL’s) attributable to the nonlife companies that had
previously constituted members of the former INA and PHC Groups
and that therefore constituted losses of ineligible companies
that could not be used to reduce income of ConnLife (the sole
life company in the consolidated CIGNA Group) -- the CIGNA Group
treated all of the companies that constituted members of the
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