Connecticut General Life Insurance Company - Page 8

                                                 - 8 -                                                   
            income earned by other companies that constituted members of the                             
            former PHC Group.                                                                            
                  On audit, for 1982 through 1985, in order to calculate the                             
            amount of net operating losses 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, respondent determined that each of the companies that                              
            constituted members of the former INA and PHC Groups should be                               
            treated as a separate entity (separate entity method), rather                                
            than merely as a part of the respective former INA and PHC                                   
            Groups.                                                                                      
                  The difference between petitioners' single entity method and                           
            respondent's separate entity method is that under petitioners’                               
            single entity method losses of the ineligible nonlife companies                              
            of the former INA and PHC Groups were, in effect, indirectly made                            
            available to reduce income of ConnLife, the life company.  Under                             
            respondent’s separate entity method losses of ineligible nonlife                             
            companies of the former INA and PHC Groups are not, to any                                   
            extent, made available to reduce income of ConnLife.                                         
                  The following schedule reflects for each of the years 1982                             
            through 1985 petitioners’ and respondent’s respective                                        
            calculations of the amount of nonlife CNOL’s that they claim                                 
            should be available under section 1503(c)(1) and (2) and the                                 
            regulations thereunder to reduce ConnLife's income:                                          




Page:  Previous  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