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Nonlife CNOL’s Eligible To Reduce Income Of ConnLife*
Petitioners' Respondent's
Year Single Entity Method Separate Entity Method
1982 ($ 34,888,309) ($10,225,979)
1983 ( 28,810,677) ( 8,351,216)
1984 ( 116,008,516) ( 26,734,260)
1985 ( 96,060,581) ( 94,424,416)
* These figures reflect CNOL’s after application
of certain percentage limitations contained in
sec. 1503.
Discussion
Summary judgment may be granted if the pleadings and other
materials demonstrate that no genuine issue exists as to any of
the material facts and that a decision may be rendered as a
matter of law. Rule 121(b); Colestock v. Commissioner, 102 T.C.
380, 381 (1994); Sundstrand Corp. v. Commissioner, 98 T.C. 518,
520 (1992), affd. 17 F.3d 965 (7th Cir. 1994).
Under section 1504(c)(2) and subject to certain limitations
not here relevant, an affiliated group of companies that includes
nonlife and life companies may elect to file consolidated Federal
income tax returns and to include the life companies in the
consolidated income tax returns. Sec. 1504(c)(2).
The above election to consolidate on a limited basis nonlife
and life companies was added to the Code as part of the Tax
Reform Act of 1976, Pub. L. 94-455, sec. 1507(a), 90 Stat. 1739,
in order that nonlife companies (such as P&C insurance companies,
which P&C industry had been experiencing losses and a diminished
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