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UNUM LIFE INS. CO. v. U.S.

No. 89-1454.

897 F.2d 599 (1990)

UNUM LIFE INSURANCE COMPANY, Plaintiff, Appellee, v. UNITED STATES of America, Defendant, Appellant.

United States Court of Appeals, First Circuit.

Decided March 6, 1990.

Attorney(s) appearing for the Case

David I. Pincus, Dept. of Justice, Tax Div., with whom Gary R. Allen and Nancy G. Morgan, Dept. of Justice, Tax Div., Shirley D. Peterson, Asst. Atty. Gen., and Richard S. Cohen, U.S. Atty., were on brief, for defendant, appellant.

Barbara H. Furey, for plaintiff, appellee.

Before BOWNES, Circuit Judge, BROWN, Senior Circuit Judge, and BREYER, Circuit Judge.

BREYER, Circuit Judge.

The question on appeal is whether certain amounts that UNUM Life Insurance Company ("UNUM") maintains to safeguard the payment of its obligations under "deposit administration contracts" (containing "annuity options" with "permanent rate guarantees") qualify as "pension plan reserves" within the meaning of § 801(b)(1) of the Internal Revenue Code of 1959, Pub.L. No. 86-89 § 2(a), 73 Stat. 112, repealed and replaced by Pub.L...

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