Legal Opinion
Best Life Assurance Company of California v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 11, 2002No. 00-71082PublishedCited by 28 opinions
1Opinion of the Court
OPINION
TALLMAN, Circuit Judge.
The Commissioner of Internal Revenue challenges the Tax Court’s determination that, because the term “unpaid losses” in Internal Revenue Code (“I.R.C.” or “Code”) § 816(c)(2) includes only unac-crued unpaid losses, taxpayer Best Life Assurance Company of California (“Best”) qualifies as a life insurance company under § 816(a). A qualified life insurance company is entitled to special tax treatment under the Code. We have jurisdiction under I.R.C. § 7482(a)(1), and we affirm.
I
Best is a California company that writes life insurance contracts and cancellable…
2Cases cited8 opinions
- Woods v. Interstate Realty Co.Supreme Court of the United States · 1949
- The Export Group Emilio Figueroa Jack Andrews v. Reef Industries, Inc., and Mexican Coffee InstituteCourt of Appeals for the Ninth Circuit · 1995
- Commissioner of Internal Rev. v. Monarch Life Ins. Co.Court of Appeals for the First Circuit · 1940
- Custom Chrome, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Robert G. Leslie and Marilyn B. Leslie v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
3 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- The Cetacean Community v. George W. Bush, President of the United States of America Donald H. Rumsfeld, United States of America Secretary of DefenseCourt of Appeals for the Ninth Circuit · 2004
- Sosa v. DIRECTV, Inc.Court of Appeals for the Ninth Circuit · 2006
- Taylor Scott v. Gino Morena EnterprisesCourt of Appeals for the Ninth Circuit · 2018
- Frank Biehl Barbara Biehl v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
- Meruelo v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
23 more not listed; retrieve them via the Exa API.