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insurance or annuity contracts
combined with noncancellable
accident and health insurance)
involving, at the time with respect
to which the reserve is computed,
life, accident, or health
contingencies.
(2) Reserves must be required by law.--Except--
(A) in the case of policies
covering life, accident, and health
insurance combined in one policy
issued on the weekly premium
payment plan, continuing for life
and not subject to cancellation, *
* *
in addition to the requirements set 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.
In a case of first impression in this Court, we must decide
whether the phrase “unpaid losses * * * not included in life
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Last modified: May 25, 2011