Legal Opinion

Central Reserve Life Corp. v. Commissioner

United States Tax Court

Decided October 12, 1999No. 21390-96Published

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

  1. Marbury v. MadisonSupreme Court of the United States · 1803
  2. Mallard v. United States Dist. Court for Southern Dist. of IowaSupreme Court of the United States · 1989
  3. Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
  4. United States v. United Mine Workers of AmericaSupreme Court of the United States · 1947
  5. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980

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