- 4 -
insurance companies also produce financial statements, which
include book income that is not included in the financial
statements of other group members.
For 1987, the total net book income attributable to life
insurance companies of the affiliated group was $199,969,459 and
that attributable to nonlife members was $2,392,675,741. For
1989, the total net book income attributable to life and to
nonlife members was $231,216,351 and a loss of $40,044,428,
respectively.
Petitioner’s 1987 and 1989 Taxable Years
During the 1987 through 1989 period, the affiliated group
comprised 2 first-tier life insurance company subsidiaries
taxable under section 801 (which, for purposes of section 1503(c)
and section 1.1502-47, Income Tax Regs., constituted the “life
subgroup”) and 11 other subsidiary corporations (which, for
purposes of section 1503(c) and section 1.1502-47, Income Tax
Regs., constituted the “nonlife subgroup”).
When petitioner originally filed its 1987 consolidated
Federal income tax return, it was not subject to the AMT imposed
by section 55. Rather, petitioner ultimately became subject to
the AMT for 1987 as a result of occurrences in 1989, namely,
Hurricane Hugo, that adversely affected the property/casualty
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