Central Reserve Life Corp. v. Commissioner
United States Tax Court
P's subsidiary, L, writes cancelable accident and health (CA&H) insurance. R argues that L is not a "life insurance company" under sec. 816(a), I.R.C., because L's accrued unpaid losses on CA&H insurance are "unpaid losses" for purposes of ascertaining its "total reserves" under sec. 816(c), I.R.C.
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P's subsidiary, L, writes cancelable accident and health (CA&H) insurance. R argues that L is not a "life insurance company" under sec. 816(a), I.R.C., because L's accrued unpaid losses on CA&H insurance are "unpaid losses" for purposes of ascertaining its "total reserves" under sec. 816(c), I.R.C. P argues that L is a life insurance company under sec. 816(a), I.R.C., because the term "unpaid losses", as used in sec. 816(c), I.R.C., does not include accrued unpaid losses on CA&H insurance. HELD: L is a life insurance company under sec. 816(a), I.R.C.; its accrued unpaid losses on CA&H…
1Opinion of the Court
CENTRAL RESERVE LIFE CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Central Reserve Life Corp. v. Commissioner
No. 21390-96
United States Tax Court
113 T.C. 231; 1999 U.S. Tax Ct. LEXIS 46; 113 T.C. No. 19;
October 12, 1999, Filed
Decision will be entered under Rule 155.
P's subsidiary, L, writes cancelable accident and health
(CA&H) insurance. R argues that L is not a "life insurance
company" under sec. 816(a), I.R.C., because L's accrued unpaid
losses on CA&H insurance are "unpaid losses" for purposes of
ascertaining its "total reserves" under sec. 816(c),…
2Cases cited56 opinions
- Marbury v. MadisonSupreme Court of the United States · 1803
- Mallard v. United States Dist. Court for Southern Dist. of IowaSupreme Court of the United States · 1989
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- United States v. United Mine Workers of AmericaSupreme Court of the United States · 1947
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
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