Trans City Life Insurance Company, an Arizona Corporation - Page 6

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                                  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.                                                             






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