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insurance operations of the nonlife subgroup in that year and
generated a nonlife subgroup net operating loss (NOL) carryback
from 1989 to 1987.
For regular tax purposes, items relevant to petitioner’s tax
liability, before any NOL deduction, would include the following:
Tax Item 1987 1989
Taxable income of nonlife subgroup 1$1,538,315,230 2($691,736,003)
Partial taxable income of life subgroup3 214,881,622 4 261,624,770
Amount subtracted under sec. 815 0 0
1 An environmental tax deduction of $2,368,957 is taken into
account in the figure stated. The parties agree that the precise
amount of the deduction will depend upon the resolution of this
case.
2 An environmental tax deduction of $0 is taken into account
in the figure stated.
3 An environmental tax deduction of $259,030 is taken into
account in the figure stated. The parties agree that the precise
amount of the deduction will depend upon the resolution of this
case.
4 An environmental tax deduction of $313,560 is taken into
account in the figure stated.
Under the regular tax regime, all of the 1989 nonlife subgroup
net operating loss of $691,736,003 is required by section 1503(c)
to be carried back to 1987 and cannot be used to offset 1989 life
subgroup partial taxable income.
For AMT purposes, adjustments and preference items under
sections 56, 57, and 58, excluding the book income adjustment and
any ATNOL deduction, are as set forth below:
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Last modified: May 25, 2011