Capital Blue Cross and Subsidiaries - Page 2

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               Peter H. Winslow and Samuel A. Mitchell, for petitioner.               
               Ruth M. Spadaro, James D. Hill, Robin L. Herrell, and                  
          Adam Trevor Ackerman, for respondent.                                       

                                       OPINION                                        
               SWIFT, Judge:  For 1994, respondent determined a deficiency            
          of $532,192 in petitioner’s Federal income tax.                             
               The issue for decision involves the allowability of                    
          $3,973,023 (hereinafter rounded to $4 million) in cumulative                
          total loss deductions claimed under section 165 relating to                 
          petitioner’s health insurance group contracts (group contracts).            
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for 1994, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
               Petitioner, Capital Blue Cross, is the common parent of an             
          affiliated group of corporations that filed consolidated                    
          corporate Federal income tax returns.  The loss deductions at               
          issue relate to the business activity of Capital Blue Cross, and            
          references to “petitioner” in the singular refer only to Capital            
          Blue Cross.                                                                 

                                     Background                                       
               Some of the facts have been stipulated and are so found.               







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