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BEST LIFE ASSURANCE COMPANY OF CALIFORNIA v. COMMISSIONER

Docket No. 11579-96.

79 T.C.M. 1909 (2000)

T.C. Memo. 2000-134

Best Life Assurance Company of California v. Commissioner.

United States Tax Court.

Filed April 12, 2000.

Attorney(s) appearing for the Case

Michael R. Schlessinger and Michael A. Clark, for the petitioner. Milton J. Carter, Jr., Gregory M. Hahn, and Keith G. Medleau, for the respondent.

MEMORANDUM OPINION

SWIFT, Judge:

For 1991 and 1992, respondent determined deficiencies in petitioner's Federal income taxes of $369,255 and $242,132, respectively.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After settlement of some issues, the issue for decision is whether petitioner (Best...

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