Connecticut General Life Insurance Company - Page 17

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            and the separate entity method reflected therein do not apply to                             
            ineligible nonlife companies that previously constituted an                                  
            affiliated and consolidated group.                                                           
                  Petitioners’ arguments that are based on certain material in                           
            the Treasury’s administrative files under section 1.1502-47(m)(3)                            
            and (4), Income Tax Regs., are not persuasive.  The documents                                
            from the administrative files are not compelling, consistent, or                             
            clear as to the intended treatment of losses of ineligible                                   
            nonlife companies that constituted part of a previously                                      
            affiliated and consolidated group.  Also, the relied-upon                                    
            material from the administrative files reflects generally only                               
            personal views of various government representatives, not                                    
            official statements of respondent or of the Treasury.  See Armco,                            
            Inc. v. Commissioner, 87 T.C. 865, 867-868 (1986).                                           
                  In any event, personal views of such government                                        
            representatives would not be able to overcome the particular                                 
            statutory and regulatory scheme before us in these cases.  In                                
            light of this statutory and regulatory scheme, petitioners’                                  
            alleged factual matter in dispute (namely, the intent of such                                
            government representatives) is simply not sufficiently relevant                              
            to the resolution of the issue to give rise to a genuine issue of                            
            material fact.  Rule 121(b).                                                                 
                  We emphasize that section 1503(c)(1) provides that nonlife                             
            losses may be taken into account only “under regulations                                     
            prescribed by the Secretary”.   Assuming arguendo that the above                             




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