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CENTRAL RESERVE LIFE CORP. & SUBS. v. COMMISSIONER

Docket No. 21390-96.

113 T.C. 231 (1999)

CENTRAL RESERVE LIFE CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

Filed October 12, 1999.

Attorney(s) appearing for the Case

Michael R. Schlessinger and Michael A. Clark, for petitioner.

Katherine Lee Wambsgans, for respondent.

OPINION

LARO, Judge:

This case is before the Court fully stipulated. See Rule 122. Central Reserve Life Corp. & Subs. petitioned the Court to redetermine respondent's determination of deficiencies of $1,936,766 and $225,070 in its consolidated Federal income tax for 1991 and 1992, respectively. Following the parties' concessions, we must decide whether the phrase "unpaid losses * * * not included in life insurance reserves" as used to define the...

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