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former INA and PHC Groups as two single, aggregate, respective
entities, and the net aggregate respective losses of the
companies that constituted members of the former INA Group and
the former PHC Group were netted against the respective taxable
income of the other companies that constituted members of the
former INA Group and the former PHC Group (single entity method).
In other words, for purposes of calculating the portion of
the net operating losses of the nonlife companies that
constituted members of the former INA Group that, on the CIGNA
Group’s consolidated Federal income tax returns for 1982 through
1985, were not allowed to reduce income of ConnLife, all
companies that constituted members of the former INA Group were
treated as a single aggregate entity, and losses of the
ineligible companies that constituted members of the former INA
Group were reduced by income earned by other companies that
constituted members of the former INA Group.
Further, for purposes of calculating the portion of the net
operating losses of the nonlife companies that constituted
members of the former PHC Group that, on the CIGNA Group’s
consolidated Federal income tax returns for 1984 and 1985, were
not allowed to reduce the income of ConnLife, all of the
companies that constituted members of the former PHC Group were
treated as a single aggregate entity, and losses of the companies
that constituted members of the former PHC Group were reduced by
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Last modified: May 25, 2011