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
OPINION
Laro, Judge:
This case is before the Court fully stipulated. See Rule 122. Central Reserve Life Corp. & Subs, petitioned the Court to redetermine respondent’s determination of deficiencies of $1,936,766 and $225,070 in its consolidated Federal income tax for 1991 and 1992, respectively. Following the parties’ concessions, we must decide whether the phrase “unpaid losses * * * not included in life insurance reserves” as used to define the term “total reserves” in section 816(c)(2) includes accrued unpaid losses on cancelable accident and health (CA&H) insurance policies.1 We hold it does…
2Cases cited54 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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3Cited by10 opinions
- Best Life Assurance Company of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002
- Anderson v. Comm'rUnited States Tax Court · 2004
- CHRYSLER CORP. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Anderson v. Comm'rUnited States Tax Court · 2004
- BEST LIFE ASSUR. CO. v. COMMISSIONERUnited States Tax Court · 2000
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