Central Reserve Life Corporation and Subsidiaries v. Commissioner

113 T.C. No. 19

UNITED STATES TAX COURT CENTRAL RESERVE LIFE CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21390-96. Filed October 12, 1999. 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",…