T.C. Memo. 2000-134
UNITED STATES TAX COURT
BEST LIFE ASSURANCE COMPANY OF CALIFORNIA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11579-96. Filed April 12, 2000.
Held: Accrued unpaid losses on cancelable
accident and health insurance policies are not to be
treated as part of total reserves in the life insurance
company qualifying fraction, and petitioner therefore
qualifies as a “life insurance company” under sec.
816(a), I.R.C. Statements made in United States v.
Occidental Life Ins. Co., 385 F.2d 1 (9th Cir. 1967)
(the Court of Appeals to which an appeal herein would
lie), do not control our holding herein.
Michael R. Schlessinger and Michael A. Clark, for
petitioner.
Milton J. Carter, Jr., Gregory M. Hahn, and Keith G. Medleau,
for respondent.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011