United States Ninth Circuit
BEST LIFE ASSURANCE CO. OF CALIFORNIA v. COMM'R OF INTERNAL REVENUE, 00-71082
Because the term "unpaid losses" in I.R.C. section 816(c)(2) includes only unaccrued unpaid losses, plaintiff qualifies as an insurance company under section 816(a), and is entitled to special tax treatment under the Tax Code.
Appellate Information
- Argued 12/03/2001
- Decided 02/11/2002
- Published 02/11/2002
Judges
- Before: BROWNING, REINHARDT, and TALLMAN, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellees:
- Michael A. Clark,Robert N. Hochman, Sidley & Austin, Chicago, IL, for petitioner-appellee Best Life Assurance Company., David I. Pincus,Robert W. Metzler, United States Department of Justice, Tax Division, Washington DC, for respondent-appellant Commissioner of Internal Revenue.