- 6 - AMT Adjustments and Preference 1987 1989 Items Nonlife subgroup $18,508,088 $70,327,213 Life subgroup 915,175 1,361,584 The parties have also stipulated that the ATNOL deduction for 1987, the total amount of which remains in dispute, will include ($189,367,790) attributable to a nonlife subgroup NOL carryover from 1986. Discussion I. General Rules A. Life-Nonlife Consolidated Returns Prior to enactment of the Tax Reform Act of 1976 (TRA 1976), Pub. L. 94-455, sec. 1507, 90 Stat. 1739, nonlife insurance companies were prohibited from filing consolidated returns with life insurance companies. See S. Conf. Rept. 94-1236, at 511 (1976), 1976-3 C.B. (Vol. 3) 807, 915. The restrictions sought to ensure that life insurance companies, traditionally profitable, paid income tax commensurate with their investment income, undiminished by the losses of often unprofitable property and casualty companies. Nichols v. United States, 260 F.3d 637, 642 (6th Cir. 2001); Conn. Gen. Life Ins. Co. v. Commissioner, 177 F.3d 136, 138 (3d Cir. 1999), affg. 109 T.C. 100 (1997). Economic considerations, however, led Congress to permit consolidation for years beginning after 1980 in order to “provide[] substantial relief in the future for casualtyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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