CONNECTICUT GENERAL LIFE INS. CO. v. C.I.R.

Nos. 97-7612, 97-7619.

177 F.3d 136 (1999)

CONNECTICUT GENERAL LIFE INSURANCE COMPANY, Appellant, v. COMMISSIONER OF INTERNAL REVENUE (Tax Court No. 92-21212). CIGNA Corporation And Consolidated Subsidiaries, Appellants, v. Commissioner of Internal Revenue (Tax Court No. 92-21213).

United States Court of Appeals, Third Circuit.

Decided April 30, 1999.


Attorney(s) appearing for the Case

A. Duane Webber (Argued), Leonard B. Terr, C. David Swenson, Baker & McKenzie, Washington, D.C. Of Counsel: Judith E. Soltz, D. Timothy Tammany, Christopher R. Loomis, CIGNA Corporation, Alfred W. Putnam, Jr., Gregg R. Melinson, Drinker Biddle & Reath, LLP, Philadelphia, PA, for Appellants, Connecticut General Life Insurance Company and CIGNA Corporation and Consolidated Subsidiaries.

Loretta C. Argrett, Assistant Attorney General, Charles Bricken, David I. Pincus, Thomas J. Clark (Argued), Department of Justice, Tax Division, Washington, D.C., for Appellee.

Before: SLOVITER, SCIRICA and ALITO, Circuit Judges.


OPINION OF THE COURT

SLOVITER, Circuit Judge.

Connecticut General Life Insurance Company, appellant in No. 97-7612, and CIGNA Corporation and Consolidated Subsidiaries (the CIGNA Group), appellants in No. 97-7619, appeal from the judgment of the United States Tax Court upholding notices of deficiency issued against them by the Commissioner of Internal Revenue in the amount of $62,176,665. For convenience, we will refer to the appellants collectively as ...

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