Northbrook Life Insurance v. Commonwealth

OPINION BY

Judge FRIEDMAN.

Northbrook Life Insurance Company (Northbrook) petitions for review of the November 20, 1996, order of the Board of Finance and Revenue (Board) of the Commonwealth of Pennsylvania (Commonwealth), which determined that, under Article XVII of The Insurance Company Law of 1921 (hereinafter, Guaranty Association Act),1 Northbrook was not entitled to offset against its 1993 premium tax liability any part of the non-taxable annuities assessment imposed on Northbrook by The Pennsylvania Life and Health Insurance Guaranty Association (Association).2

In 1993, Northbrook was…