- 15 -
for 1991, 1992, and 1993, relating to group contracts terminated
in those years, were not allowed by respondent.
In its petition filed herein on November 13, 2001,
petitioner claimed loss deductions under section 165 in the total
amount of $3,342,944 relating to the claimed cumulative total
value of the 376 group contracts terminated in 1994. No
explanation is provided as to the increase in this amount from
the $2,648,249 in total loss deductions claimed on petitioner’s
1994 corporate Federal income tax return relating to the 376
group contracts.
Subsequently, and in preparation for trial which was held in
March and April of 2003, petitioner’s trial expert witness
prepared a valuation report dated January 30, 2003, in which he
calculated, as of January 1, 1987, a cumulative total fair market
value of $4 million for the 376 group contracts that were
terminated in 1994 (based on a cumulative total fair market value
of $131,697,202 for all 23,526 of petitioner’s group contracts in
effect on January 1, 1987).7
7 The record is unclear as to how, for the 376 group
contracts terminated in 1994, petitioner’s trial expert
calculated a higher cumulative total value ($4 million) than was
calculated in petitioner’s initial valuation report ($2.6
million), even though for all 23,526 of petitioner’s group
contracts in effect on Jan. 1, 1987, petitioner’s trial expert
calculated a lower cumulative total value ($132 million) than the
initial valuation report ($163.5 million).
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011