- 6 - FINDINGS OF FACT4 1. General Facts a. Petitioner At all relevant times, petitioner was an Arizona corporation with its principal offices located in Scottsdale, Arizona. It was an “insurance company” for purposes of section 816(a), and it was authorized by the State of Arizona Department of Insurance to sell disability and life insurance within the State of Arizona. (...continued) forth in paragraph (1), life insurance reserves must be required by law. * * * * * * * (4) Amount of reserves.--For purposes of this subsection, subsection (a), and subsection (c), the amount of any reserve (or portion thereof) for any taxable year shall be the mean of such reserve (or portion thereof) at the beginning and end of the taxable year. (c) Total Reserves Defined.--For purposes of subsection (a), the term “total reserves” means-- (1) life insurance reserves, (2) unearned premiums, and unpaid losses (whether or not ascertained), not included in life insurance reserves, and (3) all other insurance reserves required by law. 4 Some of the facts have been stipulated and are so found. The stipulations and attached exhibits are incorporated herein by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011