Capital Blue Cross and Subsidiaries - Page 14

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               The total $2,648,249 in loss deductions claimed on                     
          petitioner’s 1994 corporate Federal income tax return apparently            
          constituted simply a pro rata share of the valuation reflected in           
          the initial valuation report of petitioner’s small group                    
          contracts and a pro rata share of petitioner’s large group                  
          contracts.6                                                                 
               Also, in the fall of 1995, at approximately the same time              
          that petitioner filed its 1994 corporate Federal income tax                 
          return, petitioner filed amended corporate Federal income tax               
          returns for 1991, 1992, and 1993 (the years then open under the             
          applicable refund periods of limitation) in which petitioner                
          claimed loss deductions under section 165 and tax refunds                   
          relating to the claimed cumulative total fair market value (as              
          calculated in the initial valuation report) of petitioner’s                 
          health insurance group contracts that were in effect on                     
          January 1, 1987, and that were terminated during each respective            
          year.                                                                       
               On audit, in a notice of deficiency dated August 16, 2001,             
          respondent disallowed completely the $2,648,249 in total                    
          cumulative loss deductions for 1994 relating to the 376 group               
          contracts terminated in 1994.  Also, petitioner’s claimed refunds           


               6  Because petitioner did not introduce into evidence herein           
          the initial valuation report, the particular math associated with           
          the $2,648,249 total valuation reflected therein is not in                  
          evidence.                                                                   




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