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We agree with the Court of Appeals for the Seventh Circuit
that the phrase “unpaid losses * * * not included in life
insurance reserves” as used in section 816(c)(2) to define an
insurer’s “total reserves” does not include accrued unpaid losses
on CA&H insurance policies. Our analysis starts with the
statutory text, and we construe that text in accordance with its
ordinary, everyday meaning. We refer to the legislative history
primarily to learn the purpose of the statute in which the
language appears and to resolve any ambiguity in the words used
in the text. See Landgraf v. USI Film Prods., 511 U.S. 244
(1994); Commissioner v. Soliman, 506 U.S. 168, 174 (1993);
Consumer Prod. Safety Commn. v. GTE Sylvania, Inc., 447 U.S. 102,
108 (1980); Crane v. Commissioner, 331 U.S. 1, 6 (1947); Venture
Funding, Ltd. v. Commissioner, 110 T.C. 236, 241-242 (1998);
Booth v. Commissioner, 108 T.C. 524, 568-569 (1997); Trans City
Life Ins. Co. v. Commissioner, 106 T.C. 274, 299 (1996).
The ordinary, everyday meaning of text is usually the
meaning of the words or phrases therein that is commonly
understood by the public in general; e.g., the most common
dictionary definitions. See, e.g., Mallard v. United States
Dist. Court for S. Dist., 490 U.S. 296, 301 (1989); National
Muffler Dealers Association, Inc. v. United States, 440 U.S. 472,
480 (1979); Crane v. Commissioner, supra at 6; Hefti v.
Commissioner, 97 T.C. 180, 193 (1991), affd. 983 F.2d 868 (8th
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