...1.8013 (a) of the Income Tax Regulations defines an insurance company, in part, as follows : (1) Tbe term "insurance company" means a company whose primary...year is the issuing of insurance or annuity contracts * * *. The meaning of the term "insurance company" as defined in the regulations cited above is equally...

...risks of other insurers. Section 1.801-3(a) (1) of the Income Tax Regulations provides, in part, that though its name, charter powers, and subjection to...insurance laws are significant in determining the nature of the business which a corporation is authorized and intends to carry on, the character of...

...return for such fund, but the income therefrom shall be included in the return of the corporation. (2) Though its name, charter powers, and subjection to...are significant in determining the business which a corporation is authorized and intends to carry on, the character of the business actually done in the...

...(other than a life or mutual insurance company). Section 1.801-3(a)(l) of the regulations provides that the term "insurance company" means a company whose...predominant business activity during the taxable year is the issuance of insurance contracts. Thus, though its name, charter power, and subjection to State insurance...

..."primary and predominant business activity during * * * [each of the taxable years 1958 through 1961 was] the issuing of insurance or annuity contracts or the...reinsuring of risks underwritten by insurance companies." We note at the outset that petitioner's name, charter powers, and subjection to Arizona insurance laws...

...The regulations thereunder in pertinent part expressly include "reinsurance" as life insurance: "(1) The term "insurance company" means a company whose...reinsuring of risks underwritten by insurance companies. * * * [Sec. 1.801-3(aXl), Income Tax Regs.]" See also Alinco Life Insurance Co. v. United States, 178...

...Tax Regs., refers to section 1.801-l(bX2), Income Tax Regs., which provides the following guidance: Though its name, charter powers, and subjection to...are significant in determining the business which a corporation is authorized and intends to carry on, the character of the business actually done in the...

..."primary and predominant business activity during * * * [each of the taxable years 1958 through 1961 was] the issuing of insurance or annuity contracts or the...reinsuring of risks underwritten by insurance companies." We note at the outset that petitioner's name, charter powers, and subjection to Arizona insurance laws...

...company (as defined in section 801 (a) and paragraph (b) of this section) : (a) Insurance company. (1) The term "insurance company" means a company whose...subjection to State insurance laws are significant hi determining the business which a company Is authorized and intends to carry on, it Is the character...

...return for such fund, but the income therefrom shall be included in the return of the corporation. (2) Though its name, charter powers, and subjection to...are significant in determining the business which a corporation is authorized and intends to carry on, the character of the business actually done in the...