SECTION 2. BACKGROUND

.01 Section 831 imposes a tax for each taxable year on the taxable income of every insurance company other than a life insurance company. Section 832(a) provides that, in the case of an insurance company subject to the tax imposed by § 831, the term “taxable income” means gross income, as defined in § 832(b)(1), less the deductions allowed by § 832(c).

.02 Section 832(b)(1) provides that the gross income of an insurance company subject to the tax imposed by § 831 includes

December 23, 2002 980 2002–51 I.R.B.