Legal Opinion

BEST LIFE ASSUR. CO. v. COMMISSIONER

United States Tax Court

Decided April 12, 2000No. 11579-96Unpublished

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

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. The Export Group Emilio Figueroa Jack Andrews v. Reef Industries, Inc., and Mexican Coffee InstituteCourt of Appeals for the Ninth Circuit · 1995
  3. Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
  4. Lardas v. CommissionerUnited States Tax Court · 1992
  5. Metzger Trust v. CommissionerUnited States Tax Court · 1981

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