- 17 - Amount of Year Claimed Loss Deductions 1991 $ 7,998,612 1992 7,234,627 1993 4,719,542 1994 3,973,023 1995 2,816,165 1996 3,120,934 1997 1,444,088 1998 1,750,240 1999 2,190,111 2000 1,861,149 $37,108,491 Discussion The primary issues for decision involve a legal issue and a factual issue, as follows: (1) Whether the basis step-up provision of TRA 1986 is applicable to calculations of gain or loss relating only to “sale or exchange” transactions and not to calculations of loss relating to the “termination” of assets; and (2) whether the specific and discrete fair market value, as of January 1, 1987, of the 376 group contracts terminated in 1994 has been adequately established by petitioner for purposes of the claimed loss deductions under section 165. Construction of TRA 1986 As explained, supra, in conjunction with their conversion from nontaxable to taxable status, Congress provided for Blue Cross Blue Shield organizations a fair market value basis step-up provision. The purpose of the basis step-up provision was to prevent Blue Cross Blue Shield organizations from being taxed onPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011