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USAA LIFE INSURANCE COMPANY v. COMMISSIONER

Docket No. 18187-88.

65 T.C.M. 1756 (1993)

T.C. Memo. 1993-18

USAA Life Insurance Company v. Commissioner.

United States Tax Court.

Filed January 14, 1993.

Attorney(s) appearing for the Case

Richard Bromley, Glen H. Kanwit, Michael A. Clark, and R. Lee Christie, Three First National Plaza, Chicago, Ill., for the petitioner. Avery Cousins III, for the respondent.

Memorandum Opinion

NIMS, Judge:

In our original opinion, USAA Life Insurance Co. v. Commissioner [Dec. 46,487], 94 T.C. 499 (1990), revd. without published opinion 937 F.2d 606 (5th Cir. 1991), we held that the total cash surrender value of petitioner's universal life insurance policies represented a life insurance reserve as defined in section 801(b). (Section references are to sections of the Internal Revenue Code...

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