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.
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