- 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