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BEST LIFE ASSUR. CO. OF CALIFORNIA v. C.I.R.

No. 00-71082.

281 F.3d 828 (2002)

BEST LIFE ASSURANCE COMPANY OF CALIFORNIA, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed February 11, 2002.

Attorney(s) appearing for the Case

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.

Before: BROWNING, REINHARDT, and TALLMAN, Circuit Judges.

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 unaccrued 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....

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