BEST LIFE ASSUR. CO. v. COMMISSIONER
United States Tax Court
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.
1Opinion of the Court
BEST LIFE ASSURANCE COMPANY OF CALIFORNIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
BEST LIFE ASSUR. CO. v. COMMISSIONER
No. 11579-96
United States Tax Court
T.C. Memo 2000-134; 2000 Tax Ct. Memo LEXIS 165; 79 T.C.M. (CCH) 1909;
April 12, 2000, Filed
Decision will be entered under Rule 155.
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…
2Cases cited19 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- The Export Group Emilio Figueroa Jack Andrews v. Reef Industries, Inc., and Mexican Coffee InstituteCourt of Appeals for the Ninth Circuit · 1995
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
- Lardas v. CommissionerUnited States Tax Court · 1992
- Metzger Trust v. CommissionerUnited States Tax Court · 1981
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