Connecticut General Life Insurance Company - Page 18

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            reserved subparagraph (4) of section 1.1502-47(m), Income Tax                                
            Regs., was intended and should be construed as petitioners would                             
            have us construe it (namely, as exempting from the general                                   
            separate entity method of the regulations ineligible nonlife                                 
            companies that previously had been members of an affiliated and                              
            consolidated group), petitioners arguably would be left without                              
            any specific regulatory provision that would support their single                            
            entity method for such nonlife companies.  Because section                                   
            1503(c)(1) provides that nonlife losses may be taken into account                            
            only as provided in regulations, the absence of any such                                     
            regulation might preclude petitioners from taking into account                               
            any of the losses of the ineligible nonlife companies that                                   
            previously constituted members of the former INA and PHC Groups.                             
            See Estate of Neumann v. Commissioner, 106 T.C. 216, 219-221                                 
            (1996); H Enters. Intl., Inc. v. Commissioner, 105 T.C. 71, 81-83                            
            (1995); Alexander v. Commissioner, 95 T.C. 467, 473 (1990), affd.                            
            without published opinion sub nom. Stell v. Commissioner, 999                                
            F.2d 544 (9th Cir. 1993).                                                                    
                  We simply are not persuaded by petitioners' arguments.  As                             
            indicated, the regulations in question are legislative in nature.                            
            Pursuant to sections 1502 and 1503(c)(1), the Treasury was given                             
            an express delegation of regulatory authority.  Respondent's                                 
            interpretation of the legislative regulations in these cases is                              
            sufficiently consistent with section 1503(c)(2) and its                                      
            legislative purpose to restrict the use of ineligible nonlife                                




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