- 17 - 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 abovePage: 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