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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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Last modified: May 25, 2011