Connecticut General Life Insurance Company - Page 14

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            consolidated Federal income tax returns (e.g., the companies that                            
            constituted members of the former INA and PHC Groups).                                       
                  Petitioners cite portions of the Department of the Treasury                            
            (Treasury) administrative files under section 1.1502-47(m)(3) and                            
            (4), Income Tax Regs., that suggest that the insurance industry                              
            in general and petitioners in particular were engaged with                                   
            respondent and the Treasury over a period of years in extensive                              
            discussions regarding whether a separate or a single entity                                  
            method should be adopted and reflected in the regulations with                               
            regard to the treatment of losses of ineligible nonlife companies                            
            that constituted part of a previously affiliated and consolidated                            
            group.  Portions of the referenced administrative files also                                 
            reflect positions or recommendations of various Government                                   
            officials about the separate or single entity method and indicate                            
            that some Government officials at one time or another favored a                              
            single entity method.                                                                        
                  Petitioners argue that the administrative files establish                              
            that, in the regulations, the Treasury and respondent never                                  
            adopted a final decision as to how to treat losses of ineligible                             
            nonlife companies that constituted part of a previously                                      
            affiliated and consolidated group and that the “reserved”                                    
            subparagraph (4) under section 1.1502-47(m), Income Tax Regs.,                               
            was intended to preserve this issue until that subparagraph was                              
            promulgated.                                                                                 






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