Capital Blue Cross and Subsidiaries - Page 12

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          been entitled to make adjustments in its tax books and records to           
          reflect a step up in its tax basis, for purposes of determining             
          gain or loss, relating to each of its 23,526 group contracts that           
          were in effect on January 1, 1987 (including the 376 group                  
          contracts at issue herein), from zero to an amount equal to each            
          contract’s January 1, 1987, fair market value.  During 1987                 
          through 1994, however, in petitioner’s tax books and records no             
          such tax basis adjustments were made.                                       
               Accordingly, on its originally filed corporate Federal                 
          income tax returns for 1987, 1988, 1989, 1990, 1991, 1992, and              
          1993, petitioner claimed no loss deductions under section 165               
          relating to its health insurance group contracts that were                  
          outstanding on January 1, 1987, and that were terminated during             
          each respective year.                                                       
               On its 1994 corporate Federal income tax return, petitioner            
          first claimed loss deductions under section 165 relating to                 
          terminated health insurance group contracts.                                
               As filed on approximately September 15, 1995, there was                
          reflected on petitioner’s 1994 corporate Federal income tax                 
          return loss deductions under section 165 in the cumulative total            
          amount of $2,648,249 relating to the claimed fair market value of           
          the 376 group contracts (that were among petitioner’s 23,526                









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