Connecticut General Life Insurance Company - Page 9

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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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