§801 — Tax imposed

Because respondent urges only Skidmore deference, we need not decide how the Ninth Circuit would resolve this question.

During the years 1996 through 2002 petitioner was the common parent of an affiliated group of corporations that included two domestic life insurance companies taxable under section 801 (life subgroup) and a varying number of domestic nonlife insurance companies and other domestic corporations (nonlife subgroup, and together with the life subgroup, consolidated group) .

State Farm is also the common parent of an affiliated group including domestic life insurance companies taxed under section 801, domestic nonlife insurance companies, and other domestic corporations.

x reporting purposes. HCA's Tax Department retained the results of the computations made in arriving at cash method taxable income as shown on petitioners' Federal income tax returns and made those results 11 Sec. 448, which was added to the Code by sec. 801 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2345, wherein Congress required certain corporations, including hospitals, to change prospectively beginning in 1987 to an overall accrual method, does not apply to the accounting issu

x reporting purposes. HCA's Tax Department retained the results of the computations made in arriving at cash method taxable income as shown on petitioners' Federal income tax returns and made those results 11 Sec. 448, which was added to the Code by sec. 801 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2345, wherein Congress required certain corporations, including hospitals, to change prospectively beginning in 1987 to an overall accrual method, does not apply to the accounting issu

During the years 1996 through 2002 petitioner was the common parent of an affiliated group of corporations that included two domestic life insurance companies taxable under section 801 (life subgroup) and a varying number of domestic nonlife insurance companies and other domestic corporations (nonlife subgroup, and together with the life subgroup, consolidated group).

State Farm is also the common parent of an affiliated group including domestic life insurance companies taxed under section 801, domestic nonlife insurance companies, and other domestic corporations.

801(2), describe it as "[t]he illegal importation, manufacture, distribution, and possession and improper use ofcontrolled substances". Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes

801(2), describe it as "[t]he illegal importation, manufacture, distribution, and possession and improper use ofcontrolled substances". Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes

801(2), describe it as "[t]he illegal importation, manufacture, distribution, and possession and improper use ofcontrolled substances". Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes

801(2), describe it as "[t]he illegal importation, manufacture, distribution, and possession and improper use ofcontrolled substances". Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes

801(2), describe it as "[t]he illegal importation, manufacture, distribution, and possession and improper use ofcontrolled substances". Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes

801(2), describe it as "[t]he illegal importation, manufacture, distribution, and possession and improper use ofcontrolled substances". Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes

at 264; see also Alli v.

cise investment control over the account, but he could no longer surrender the policy. The policy in Revenue Ruling 77-85 was meant to qualify as a “variable contract” based on a “segregated asset account” within the meaning of section 817(d) (then section 801(g)). But for this treatment to be available, the IRS noted, “the insurance company must be the owner of the assets in the segregated accounts.” Id., 1977-1 C.B. at 14. The IRS concluded that the taxpayer possessed such significant incident

ation oftrusts and generally coordinates the passive-activity-lossrules ofsec. 469 with the rules on taxation oftrusts in subch. J. See, e.g., 1 Byrle K. Abbin, David K. Carlson, and Mark L. Vorsatz, Income Taxation ofFiduciaries and Beneficiaries, sec. 801, at 8003 to 8004 (2012 ed.) ("Section 469 does not easily comport with subchapter J. To date no regulatory explanation has been forthcoming * * * [on questions including] where and how material participation is measured[.]"); M. Carr Ferguson

n of trusts and generally coordinates the passive-activity-loss rules of sec. 469 with the rules on taxation of trusts in subch. J. See, e.g., 1 Byrle K. Abbin, David K. Carlson, and Mark L. Vorsatz, Income Taxation of Fiduciaries and Beneficiaries, sec. 801, at 8003 to 8004 (2012 ed.) (“Section 469 does not easily comport with subchapter J. To date no regulatory explanation has been forthcoming * * * [on questions including] where and how material participation is measuredL]”); M. Carr Ferguson

494, 985, in order to comply with the General Agreement on Tariffs and Trade, see S. Prt. 98-169 (Vol. I), at 635 (Comm. Print 1984). Under the FSC provisions, a taxpayer may permanently exclude - 19 - from Federal income tax a portion of its profits from qualifying export sales.3 Both the DISC and the FSC provisions reallocate

In that case, the parties stipulated that unpaid losses in section 801 (now section 816) - 12 - had the same meaning as unpaid losses in former section 806.

The parties in that case had stipulated that the term had the same meaning in former sections 801 and 806(c), and the court construed section 816's predecessor (former section 801) merely as support for its ultimate conclusion.

The parties in that case had stipulated that the term had the same meaning in former sections 801 and 806(c), and the court construed section 816’s predecessor (former section 801) merely as support for its ultimate conclusion.

Section 864(c)3 and the 2Sec. 842(a) provides in pertinent part: (a) Taxation under this subchapter.--If a foreign company carrying on an insurance business within the United States would qualify under part I * * * of this subchapter for the taxable year if (without regard to income not effectively connected with the conduct of any

ns. For the consolidated return filed for the year ended 1987, pursuant to section 448,3 petitioners not employing an overall accrual method for computing taxable income for the years ended 3 Sec. 448, which was added to the Internal Revenue Code by sec. 801 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2345, provides generally that, with certain exceptions not applicable in the instant case, a C corporation, a partnership that has a C corporation as a partner, or a tax shelter may no

mbia Healthcare Corp. of Louisville, Ky., and the subsidiary changed its name to HCA-Hospital Corp. of America. On that same date, the parent changed its name to Columbia/HCA Healthcare Corp. Sec. 448, which was added to the Internal Revenue Code by sec. 801 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2345, provides generally that, with certain exceptions not applicable in the instant case, a C corporation, a partnership that has a C corporation as a partner, or a tax shelter may no

Rept. 98-861, at 1043-1044 (1984), 1984-3 C.B. (Vol. 2) 1, 297-298. This change necessitated treating the product of the deficiency and the foreign insurance company’s actual yield as additional effectively connected income instead of as a reduction of certain deductions which was done under the previous section 819. Subsequently,

801 of the DRA created a similar vehicle; i.e., the Foreign Sales Corp. (FSC), in secs. 921 through 927 to carry forward the Congress' intent to stimulate United States exports. Many of the FSC provisions, including the definition of export property in sec. 927, mirror (or are substantially similar to) the corresponding DISC provision. - 11 -