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
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