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Accordingly, based on its trial expert’s valuation of the
376 group contracts, petitioner now claims total loss deductions
for 1994 under section 165 in the amount of $3,973,023 (an
increase of $1,324,774 over the $2,648,249 in total loss
deductions claimed therefor on petitioner’s 1994 corporate
Federal income tax return).
Further, on March 31, 2002, petitioner filed second amended
corporate Federal income tax returns for 1992 and 1993,
increasing for those years the total loss deductions claimed
under section 165 relating to terminated group contracts for
those years.
For years after 1994, petitioner continued to claim loss
deductions under section 165 relating to the value of
petitioner’s group contracts in effect on January 1, 1987, that
were terminated in each respective year.
For 1991 through 2000, the loss deductions claimed by
petitioner under section 165 relating to petitioner’s valuation
of group contracts terminated in each year (that were in effect
on January 1, 1987) total approximately $37 million as set forth
below:
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