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CAPITAL BLUE CROSS & SUBS. v. COMMISSIONER

Docket No. 13322-01.

122 T.C. 224 (2004)

122 T.C. No. 11

CAPITAL BLUE CROSS AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 12, 2004.

Attorney(s) appearing for the Case

Peter H. Winslow and Samuel A. Mitchell, for petitioner.

Ruth M. Spadaro, James D. Hill, Robin L. Herrell, and Adam Trevor Ackerman, for respondent.

OPINION

SWIFT, Judge:

For 1994, respondent determined a deficiency of $532,192 in petitioner's Federal income tax.

The issue for decision involves the allowability of $3,973,023 (hereinafter rounded to $4 million) in cumulative total loss deductions claimed under section 165 relating to petitioner's health insurance group contracts (group contracts).

Unless otherwise indicated, all section references are to the Internal Revenue Code...

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