- 2 -
Jerome B. Libin, James V. Heffernan, and Mary E. Monahan,
for petitioner.
Jan E. Lamartine, for respondent.
OPINION
COHEN, Judge: Respondent determined a Federal income tax
deficiency in the amount of $1,235,690 with respect to the 1987
taxable year of State Farm Mutual Automobile Insurance Co. and
Subsidiaries (herein collectively petitioner). By answer,
respondent asserted an increased deficiency of $2,827,110. The
principal issue for decision is the computation of petitioner’s
alternative minimum tax (AMT) liability for 1987, which in turn
will involve consideration of the amount of petitioner’s
alternative tax net operating loss (ATNOL) carryback from 1989.
Integral to each of these calculations is the question of how
properly, in the context of the consolidated return of an
affiliated group of life and nonlife insurance companies, to take
into account the alternative minimum tax book income adjustment
of section 56(f).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for relevant years, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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