- 9 - 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 diminishedPage: 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