INTERNATIONAL LIFE INSURANCE COMPANY v. COMMISSIONER

Docket No. 1307-67.

51 T.C. 765 (1969)

INTERNATIONAL LIFE INSURANCE COMPANY (FORMERLY STATE INSURANCE CO. OF KENTUCKY), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 17, 1969.


Attorney(s) appearing for the Case

Harry L. Brown, for the petitioner.

John J. Larkin and Dennis M. Feeley, for the respondent.


TANNENWALD, Judge:

The respondent determined deficiencies in the income tax of petitioner for the years 1960 and 1961 in the amounts of $31,704.08 and $54,339.10. The issue for our consideration is the existence and extent of a net operating loss in 1957, which it is conceded can be carried over to the subsequent taxable years. The resolution of this issue depends upon whether petitioner erroneously reported certain unearned premiums and liabilities assumed...

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