State Farm Mutual Automobile Insurance Company and Subsidiaries - Page 8




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                    consolidated net operating loss for such taxable                  
                    year, then under regulations prescribed by the                    
                    Secretary, the amount of such loss which cannot be                
                    absorbed in the applicable carryback periods                      
                    against the taxable income of such members not                    
                    taxed under section 801 shall be taken into                       
                    account in determining the consolidated taxable                   
                    income of the affiliated group for such taxable                   
                    year to the extent of 35 percent of such loss or                  
                    35 percent of the taxable income of the members                   
                    taxed under section 801, whichever is less.  The                  
                    unused portion of such loss shall be available as                 
                    a carryover, subject to the same limitations                      
                    (applicable to the sum of the loss for the                        
                    carryover year and the loss (or losses) carried                   
                    over to such year), in applicable carryover years.                
               Section 1.1502-47, Income Tax Regs., was promulgated to                
          govern consolidated returns by life-nonlife groups.  The                    
          regulations generally adopt a “subgroup method” for determining             
          consolidated taxable income.  Sec. 1.1502-47(a)(2)(i), Income Tax           
          Regs.  This method divides the affiliated group into a life                 
          subgroup and a nonlife subgroup.  Id.; sec. 1.1502-47(d)(8) and             
          (9), Income Tax Regs.  Consolidated taxable income for the group            
          is then defined as the sum of:  (1) Nonlife consolidated taxable            
          income, as set off by allowable life losses; (2) consolidated               
          partial life insurance company taxable income (consolidated                 
          partial LICTI), as set off by allowable nonlife losses; and                 
          (3) amounts subtracted under section 815 from life policyholders’           
          surplus accounts.  Sec. 1.1502-47(g), Income Tax Regs.                      
               Nonlife consolidated taxable income, in turn, aggregates the           
          separate taxable incomes of the nonlife members, with specified             
          consolidated adjustments, and incorporates reductions for current           





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