Lone Star Life Insurance Company - Page 2

                                        - 2 -                                         

          ground that the notice of deficiency underlying the petition                
          constitutes an improper second notice of deficiency under section           
          6212(c).1                                                                   
          Background2                                                                 
               During the taxable years 1988 through 1991, Lone Star Life             
          Insurance Co. was a wholly owned subsidiary of  Hibiscus Life               
          Insurance Co. (Hibiscus).  Hibiscus timely filed consolidated               
          Federal income tax returns, Forms 1120L, pursuant to section 1501           
          for the taxable years 1988, 1989, 1990, and 1991 on September 14,           
          1989, September 17, 1990, September 16, 1991, and September 14,             
          1992, respectively.3                                                        
               During the years in issue, Hibiscus and petitioner shared              
          common corporate officers as well as the same mailing address.              
          In particular, Jerry Marshall served as controller for Hibiscus             
          and vice president and controller for petitioner, while Gary                
          Powers served as treasurer for Hibiscus and vice president                  
          (finance and treasurer) for petitioner.                                     
               Revenue Agent Anita Kate Barrett conducted an examination of           
          Hibiscus' consolidated tax returns for the taxable years 1988               

          1  Unless otherwise indicated, all section references are to                
          the Internal Revenue Code as amended.  Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
          2  The following is a summary of the relevant facts that do                 
          not appear to be in dispute; they are stated solely for purposes            
          of deciding the pending motion and are not findings of fact for             
          these cases.                                                                
          3  During the years in issue, petitioner was Hibiscus' sole                 
          subsidiary.                                                                 


Page:  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