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SEARS, ROEBUCK AND CO. v. C.I.R.

Nos. 91-3038, 91-3688.

972 F.2d 858 (1992)

SEARS, ROEBUCK AND CO. and Affiliated Corporations, Petitioner-Appellant, Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Cross-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided August 18, 1992.

As Amended on Denial of Rehearing October 14, 1992.

Attorney(s) appearing for the Case

Michael M. Conway (argued), Frederic W. Hickman, Michael R. Schlessinger, Patrick A. Heffernan, Bradford L. Ferguson, Burton H. Litwin, Hopkins & Sutter, Chicago, Ill., petitioner-appellant, cross-appellee.

Abraham N.M. Shashy, Jr., I.R.S., Gary R. Allen, David I. Pincus (argued), John A. Dudeck, Jr., Mary F. Clark (argued), Dept. of Justice, Tax Div., Appellate Section, Washington, D.C., for respondent-appellee, cross-appellant.

Francis M. Gregory, Jr., Dennis L. Allen, George R. Abramowitz, Sutherland, Asbill & Brennan, Washington, D.C., amicus curiae Mortgage Ins. Companies of America.

Carolyn J. Johnson, National Ass'n of Ins. Com'rs, Kansas City, Mo., amicus curiae National Ass'n of Ins. Com'rs.

Frederic W. Hickman, Richard Bromley, Hopkins & Sutter, Chicago, Ill., Robert L. Zeman, Patrick J. McNally, National Ass'n of Independent Insurers, Des Plaines, Ill., amicus curiae National Ass'n of Independent Insurers.

Before BAUER, Chief Judge, EASTERBROOK, Circuit Judge, and NOLAND, Senior District Judge.

EASTERBROOK, Circuit Judge.

Several subsidiaries of Sears, Roebuck & Co. sell insurance. One, Allstate Insurance Co., underwrote some of the risks of the parent corporation. Two others wrote mortgage insurance, promising to pay lenders if borrowers defaulted. Because Sears and all other members of the corporate group file a consolidated tax return, disputes about the tax consequences of these transactions affect the taxes of the entire

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