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Cir. 1993). In the case at hand, however, the text of section
816 is found in subchapter L of the Code. Congress drafted
subchapter L and its predecessors using the specialized language
of the insurance industry, and Congress understood that language
to have the technical meaning given to it by that industry. See
Helvering v. Independent Life Ins. Co., 292 U.S. 371, 379 (1934);
Alinco Life Ins. Co. v. United States, 178 Ct. Cl. 813, 373 F.2d
336, 352 (1967); see also United States v. American Trucking
Associations, Inc., 310 U.S. 534, 543-544 (1940). It is only
appropriate, therefore, to construe the subject text in the light
of its usage in the insurance industry, to the extent that it has
an established meaning in that industry. See Atlantic Mut. Ins.
Co. v. Commissioner, 523 U.S. 382 (1998); Hedden v. Richard, 149
U.S. 346, 348-349 (1893); South Jersey Sand Co. v. Commissioner,
30 T.C. 360, 368 (1958), affd. 267 F.2d 591 (3d Cir. 1959). The
meaning of the words in the insurance industry may be gleaned
from their use in the annual statement which contains,
references, and incorporates many of the industry’s terms of art.
The annual statement is instructive in understanding the peculiar
meaning of those words, which, in turn, may make it most helpful
in construing the provisions of subchapter L. See Commissioner
v. Standard Life & Accident Ins. Co., 433 U.S. 148, 157-163
(1977); Harco Holdings, Inc. v. United States, supra at 1033.
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