Trans City Life Insurance Company, an Arizona Corporation - Page 41

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          v. Commissioner, 105 T.C. 71, 81-85 (1995).                                 
               We are mindful that a vital component of due process is that           
          a statute be "reasonably clear".  See Smith v. Goguen, 415 U.S.             
          566, 572 (1974); Grayned v. City of Rockford, 408 U.S. 104,                 
          108-109 (1972); Retired Teachers Legal Defense Fund, Inc. v.                
          Commissioner, 78 T.C. 280, 284-285 (1982).  We conclude that                
          section 845(b) passes that test.  As will be reflected in the               
          following discussion, the term "significant tax avoidance effect"           
          has a discernible meaning taking into account the relevant                  
          legislative history and other aids to its interpretation.                   
          3.  Significant Tax Avoidance Effect                                        
               Respondent determined that the Agreements had a significant            
          tax avoidance effect with respect to petitioner.  Respondent                
          argues that the Agreements did not transfer life insurance risk             
          to petitioner that was proportionate to the benefit it derived              
          from the small life insurance company deduction.  Respondent                
          relies primarily upon the testimony of her three experts,                   
          Ralph J. Sayre, Jack M. Turnquist, and Charles M. Beardsley.                
          Mr. Sayre is a consulting actuary for Actuarial Resources of                
          Georgia, and he is a member of various actuarial societies.                 
          Mr. Turnquist is a member of various actuarial organizations, and           
          he has been self-employed since 1987, providing consulting                  
          services on actuarial and technical communications relative to              
          the operation of life insurance companies.  Mr. Beardsley is an             
          actuary, and he is an expert on the annual statement reporting              
          for insurance companies.                                                    





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