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the denominator of Best Life's life insurance company qualifying
fraction. Based thereon, respondent determined that Best Life
did not qualify as a life insurance company as defined under
section 816(a). Accordingly, respondent disallowed the claimed
life insurance company deductions under section 806.
We recently decided this same issue in favor of another
insurance company in Central Reserve Life Corp. & Subs. v.
Commissioner, 113 T.C. 231 (1999), which followed the Court of
Appeals for the Seventh Circuit's 1992 opinion and analysis in
Harco Holdings, Inc. v. United States, 977 F.2d 1027, 1029 (7th
Cir. 1992), revg. 754 F. Supp. 130 (N.D. Ill. 1990). We follow
the holdings and the analyses set forth in those two opinions.
Therein, it is recognized that Congress promulgated sections
801 through 818 using the specialized language of the insurance
industry and that Congress generally intended the language of
sections 801 through 818 to be given the technical meaning used
by the insurance industry. See Harco Holdings, Inc. v. United
States, 977 F.2d at 1030; Central Natl. Life Ins. Co. v. United
States, 216 Ct. Cl. 290, 574 F.2d 1067, 1074 (1978) (“the
definitions combine the 'labyrinthine composition' of the tax law
with the 'mystic processes' in life insurance reserves; they were
not 'written for ordinary folk.'”)(fn. ref. omitted); Alinco Life
Ins. Co. v. United States, 178 Ct. Cl. 813, 373 F.2d 336, 352-353
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