113 T.C. No. 19 UNITED STATES TAX COURT CENTRAL RESERVE LIFE CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21390-96. Filed October 12, 1999. P's subsidiary, L, writes cancelable accident and health (CA&H) insurance. R argues that L is not a “life insurance company" under sec. 816(a), I.R.C., because L's accrued unpaid losses on CA&H insurance are “unpaid losses" for purposes of ascertaining its “total reserves" under sec. 816(c), I.R.C. P argues that L is a life insurance company under sec. 816(a), I.R.C., because the term “unpaid losses", as used in sec. 816(c), I.R.C., does not include accrued unpaid losses on CA&H insurance. Held: L is a life insurance company under sec. 816(a), I.R.C.; its accrued unpaid losses on CA&H insurance are not “unpaid losses” for purposes of sec. 816(c), I.R.C.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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