Unum, Corporation v. USA

Case Date: 12/01/1997
Court: United States Court of Appeals
Docket No: 96-1877









United States Court of Appeals United States Court of Appeals
For the First Circuit For the First Circuit
____________________

No. 96-1877

UNUM CORPORATION AND UNUM LIFE
INSURANCE COMPANY OF AMERICA,

Plaintiff-Appellant,

v.

UNITED STATES OF AMERICA,

Defendant-Appellee.

____________________


APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MAINE

[Hon. Gene F. Carter, U.S. District Judge] ___________________

____________________

Before

Torruella, Chief Judge, ___________
Aldrich, Senior Circuit Judge, ____________________
and Lynch, Circuit Judge. _____________
____________________

William J. Kayatta, Jr., with whom Jared S. des Rosiers, _______________________ _____________________
Pierce Atwood, Barbara H. Furey, Barry W. Larman, and UNUM ______________ _________________ ________________ ____
Corporation and UNUM Life Insurance Company of America were ________________________________________________________
on brief for appellant.

Edward T. Perelmuter, Tax Division, Department of ______________________
Justice, with whom Loretta C. Argrett, Assistant Attorney ___________________
General, and David I. Pincus, Tax Division, Department of ________________
Justice, were on brief for appellee.

____________________

December 2, 1997
____________________



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LYNCH, Circuit Judge. The need to raise capital LYNCH, Circuit Judge. _____________

and to compete in increasingly diversified financial markets

has led a number of American mutual life insurance companies

to convert to being stock companies. This process, known as

"demutualization," often involves a conversion of the mutual

policyholders' ownership interest in the old company into

ownership interest in the form of stock in the new company.

This appeal raises important questions about the

proper tax treatment of one form of demutualization: whether

stock and cash distributed to policyholders in exchange for

their mutual ownership interests as part of a statutory

demutualization constitute "policyholder dividends" under

808 of the Internal Revenue Code. If so, the insurer may

take a deduction for "policyholder dividends" under

805(a)(3). Whether the "policyholder dividends" deduction

is available has great financial consequences for the company

and for the public fisc. This question involves

consideration of the scope of the "policyholder dividend"

under 808, as well as the broader relationship between the

general corporate tax provisions of the Code (contained in

Subchapter C) and the Code's insurance tax provisions

(contained in Subchapter L).

In this case, UNUM Corp. ("UNUM"), the demutualized

successor to Union Mutual Life Insurance Co. ("Union

Mutual"), seeks a tax refund based on a "policyholder



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dividends" deduction of over $652 million. This sum, which

UNUM was required to distribute to its policyholders by state

law, represents the value of Union Mutual's accumulated

surplus. See Me. Rev. Stat. Ann. tit. 24-A, 3477 (West ___

1996).

UNUM's principal argument is that the cash and

stock distributed during the demutualization constitute

"policyholder dividends" under the plain language of 808(b)

and thus are deductible under 805. UNUM further argues

that, beyond the statute's plain language, the legislative

history and public policy behind the Code's treatment of life

insurance companies support this result.

The IRS argues that general corporate tax

provisions apply to insurance companies in the absence of

specific provisions to the contrary in the Code's insurance

tax section, and that, under those corporate tax provisions,

UNUM is not entitled to any deduction for its reorganization.

The IRS argues that nothing in 808 or its legislative

history indicates that Congress envisioned 808 as

encompassing capital transactions such as UNUM's

demutualization. Rather, placed in proper context, 808 is

not relevant to the value-for-value exchanges for which UNUM

seeks a deduction.







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The district court entered judgment for the

government in UNUM's suit for a refund. We affirm the

judgment of the district court.

I I

This appeal involves only questions of law; we

exercise de novo review. Alexander v. Internal Revenue ________ _______________________________

Service, 72 F.3d 938, 941 (1st Cir. 1995). The parties have _______

agreed on the facts.

A. Background __________

Demutualization has become increasingly common in

the insurance industry. More than 200 mutual life insurance

companies have demutualized since 1930. See S. Preston ___

Ricardo, The Deductibility of Policyholder Dividends: UNUM ___________________________________________________

Corp. v. United States, 50 Tax Law. 265, 265 (1996). Between ______________________

1954 and 1981, the number of mutual insurers declined from

171 to 135; during the same time, the number of stock

insurers increased from 661 to 1,823. Edward X. Clinton, The ___

Rights of Policyholders in an Insurance Demutualization, 41 _________________________________________________________

Drake L. Rev. 657, 659 n. 13 (1992). Today, fewer than 80

mutual insurers have assets of over $100 million. See ___

William B. Dunham, Jr., et al., Introduction, in ____________ __

Demutualization of Life Insurers, 648 PLI/Comm 9, 16 (1993). _________________________________

These figures suggest that mutual insurers are rapidly

demutualizing, and that new insurance companies prefer the

stock form at the outset.



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State legislatures have facilitated this

demutualization process by passing statutes permitting such

conversions. Presently, at least forty-one states have

specific statutes that provide for demutualization of mutual

life insurers. Alexander M. Dye, Distributing Consideration __________________________

to Policyholders, in Demutualization of Life Insurers, 648 ________________ __ _________________________________

PLI/Comm 75, 78 (1993). Only Hawaii and Idaho expressly

prohibit direct mutual to stock conversion, although they

still permit demutualization through the alternate method of

bulk reinsurance conversion. See Clinton, supra, at 673 n. ___ _____

116. Every state, including those that lack specific

demutualization statutes, permits at least some form of

demutualization. See id. ___ ___

There are three usual types of mutual to stock

conversions: a statutory conversion whereby the insurer

directly converts its form of business, merger with a stock

insurer, and bulk reinsurance of the mutual company's

policies. See id. at 660-61. This case only concerns the ___ ___

first type of conversion: a statutory conversion, in which a

mutual company alters its organizational form to become a

stock insurer by redistributing all the mutual policyholder's

ownership interest in the mutual insurer into shares of stock

in a new stock corporation. "This type of reorganization may

properly be regarded as a reorganization of the company





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because the policyholders are exchanging membership in the

mutual for shares in the new corporation." Id. at 660. ___

By demutualizing, mutual insurers can obtain

certain advantages available to stock insurers. Stock

corporations are better able to raise capital because they

may sell stock on the equity markets. See id. at 666-671. ___ ___

Stock companies can more easily diversify their operations by

creating upstream holding companies which can own

subsidiaries engaged in other businesses. See id. at 671-72. ___ ___

They can also create incentives for superior management

performance through stock option plans. See id. at 672-74. ___ ___

Mutual insurers can only raise capital by retaining earnings

or charging excess premiums, and are generally subject to

comprehensive regulation by state authorities. These

limitations can hinder their ability to grow and diversify.

See id. at 666. ___ ___

Much is at stake in this process. Mutual insurance

companies have historically lagged behind stock insurers in

growth of assets and capital. Demutualization and subsequent

stock sales may improve a mutual insurer's capital position

and competitive standing with other insurers and financial

institutions. Mutual insurers naturally want to contend in

the increasingly competitive and deregulated financial

services markets. Many mutual insurers regard





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demutualization as an important step toward bolstering their

financial strength and flexibility.

B. Facts _____

Union Mutual, based in Maine, was organized as a

mutual insurance company in 1848. Union Mutual's business

was selling various types of insurance and annuity products.

As a mutual company, Union Mutual had no stock and was owned

by its participating policyholders.1 Policyholders

contributed to Union Mutual's surplus by paying premiums that

exceeded the actuarial cost of their policy coverage.

In 1984, Union Mutual's management decided to

reorganize the company as a stock insurer. The management

decided that the company would gain four principal business

advantages from this conversion: an increased ability to


____________________

1. Mutual life insurance companies do not raise money by
issuing capital stock, but rather by charging policyholders a
"redundant premium" that exceeds the amount actuarially
anticipated to pay the policy's benefits and expenses. The
excess portions of these premiums are accumulated, retained,
and invested as "surplus".
A mutual insurer's accumulated surplus is the excess of
assets over liabilities. Such an excess results from the
accumulation of redundant premiums and investment earnings
over the life of the company. Surplus generally belongs to
the mutual insurer's members in proportion to their
contributions, and is generally returned to policyholders
through policyholder dividends.
Mutual insurers are thus owned by their policyholders.
Policyholders in mutual companies are denominated "members"
of the company; their ownership rights in the company are
their "membership interests". Members of mutual insurance
companies have many of the same rights as stockholders in
corporations, including the right to vote and the right to
residual surplus upon liquidation.

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raise capital, greater flexibility to diversify into new

markets, an increased accountability for company performance

by management, and an enhanced ability to attract and retain

key personnel.

Under Maine law, Union Mutual was not permitted to

implement its conversion plan until the plan was approved by

the Maine Superintendent of Insurance. See Me. Rev. Stat. ___

Ann. tit. 24-A, 3477 (West 1996). Maine law imposes

several conditions that a demutualization plan must satisfy

in order to receive approval by the Superintendent. These

include, inter alia, (1) that the company pay policyholders a _____ ____

"fair and equitable" amount for their ownership interests in

the company, (2) that the "equity share" of each policyholder

be determined under a fair and reasonable formula based upon

the insurer's entire surplus as stated in a financial

statement filed with the Superintendent, (3) that the

conversion plan give each member of the demutualizing insurer

a preemptive right to acquire his or her proportionate part

of the proposed capital stock of the new stock company, (4)

that the plan provide for payment to each member of his or

her entire equity share in the insurer, with the payment to

be made in cash or stock of the stock company, and (5) that

policyholders entitled to receive stock or cash include all

policyholders within three years prior to the date the plan

was submitted for approval to the Superintendent. See id. ___ ___



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On December 14, 1984, Union Mutual submitted a plan

of recapitalization and conversion to the Superintendent.

Union Mutual amended the plan several times in response to

rulings by the Superintendent. On July 11, 1986, Union

Mutual submitted its fourth and final amended plan, which was

approved by the Superintendent on August 8, 1986.

The approved plan of conversion may be generally

described as follows. A holding company was formed to own

all the stock of the new stock company. Those who were

"eligible policyholders"2 transferred their "membership

interests" in Union Mutual to the holding company in exchange

for stock in the holding company. "Membership interests"

were defined in the conversion plan as:

[A]ll the rights or interests of each
policy and contract holder of Union
Mutual including, but not limited to, any
right to vote, any rights which may exist
with regard to the surplus of Union
Mutual not apportioned by the Board for
policyholder dividends, and any rights in
liquidation or reorganization of Union
Mutual, but shall not include any other
right expressly conferred by a
policyholder's insurance policy or
contract.








____________________

2. "Eligible policyholders" were generally defined in the
conversion plan as all Union Mutual policyholders during the
three years prior to December 31, 1984.

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Eligible policyholders who qualified as "cash

option eligible policyholders"3 could elect to exchange their

membership interests for cash instead of stock. The holding

company, after obtaining 100% of the membership interests in

Union Mutual, exchanged the membership interests for 100% of

the shares of the newly formed stock insurer. The holding

company sold stock not issued to policyholders to insiders

and the general public. At the conclusion of the Plan, UNUM

Life Insurance Co. ("UNUM Life"), the new stock company, was

a wholly owned subsidiary of UNUM, the holding company. UNUM

was in turn owned by former Union Mutual policyholders,

insiders, and members of the general public.

The approved plan included an actuarial formula for

calculating the consideration to be paid to each policyholder

in exchange for his or her membership interest in Union

Mutual. This figure, denominated each policyholder's "equity

share" in Union Mutual, was defined as "the dollar amount of

that part of Union Mutual's Adjusted Surplus attributable to"

the particular policyholder. Each policyholder's "equity

share" comprised two components: a "minimum equity share"

and the individual's "contribution to statutory surplus". On

December 31, 1985, the day Union Mutual presented its

consolidated balance sheet for final review by the

____________________

3. "Cash option eligible policyholders" were generally
defined in the conversion plan as policyholders with equity
of less than $2,500 in Union Mutual.

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Superintendent, Union Mutual's adjusted surplus was

$652,050,097.4 Based on that figure, Union Mutual's

management determined that each policyholder should receive a

per capita amount of $612.25 as the "minimum equity share".

The "contribution to statutory surplus" varied by individual

policyholder. The formula for computing a policyholder's

"equity share" that is referred to in the plan of conversion

reveals this two-component scheme.

The plan of conversion also provided for creation

of an accounting mechanism known as a Participation Fund

Account ("PFA"). The PFA created the functional equivalent

of a closed block5 and was allocated assets which, together

____________________

4. Surplus can be measured by either statutory accounting
principles or generally accepted accounting principles
("GAAP"). The difference between the two methods is
primarily one of timing: the costs of selling policies are
fully charged when incurred under statutory accounting
principles, but are amortized over the expected life of the
policies under GAAP. UNUM's accumulated surplus of
$652,050,097 was calculated under GAAP.
In UNUM's demutualization plan, "surplus" was defined as
"the amount of the surplus of Union Mutual as shown by its
financial statement as of the Computation Record Date
(December 31, 1985) filed with the Superintendent, as may be
confirmed or adjusted in the event of an examination by the
Superintendent, including all voluntary reserves but without
taking into account the value of nonadmitted assets or of
insurance business in force."

5. Some states protect the policyholders by requiring that a
mutual insurer establish a "closed block" of business as a
condition of demutualization. See N.Y. Ins. Laws. 7312 ___
(West 1997); 40 Pa. Cons. Stat. Ann. 915-A (West 1997).
Such statutes generally require the mutual insurer's policies
and contracts in force at the time of the reorganization be
placed by the reorganized insurer into a "closed block" into
which the insurer must allocate assets that, together with

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with premiums from the participating policies, were

actuarially sufficient to pay policy claims and policyholder

dividends. Under the conversion plan, the amount of the

assets in the PFA could not be distributed to stockholders of

the demutualized insurer. As with a closed block, it had to

be invested and used for the exclusive benefit of the

policyholders. The PFA was designed with the aim that Union

Mutual's policyholders would continue to receive policyholder

dividends after the demutualization at the same level as

before, even though policyholders and stockholders would have

competing claims on the earning and profits of the company.

The PFA thus was meant to assure policyholders that their

reasonable expectations about the investment value of their

policies would continue to be met.

The creation of the PFA was an important

consideration in the Superintendent's decision to approve the

demutualization plan. In his Final Decision and Order, the

Superintendent discussed the PFA at some length, observing

that Union Mutual policyholders had bought their policies

____________________

revenue, are sufficient to pay policy claims and policyholder
dividends. Thereafter, the insurer may not distribute any
earnings or proceeds developed within that block to
stockholders. The closed block must be operated for the
exclusive benefit of the included policies and contracts,
distributions being for policyholder dividend purposes only.
See id.; Dye, supra at 115-116. ___ ___ _____
A PFA may be required as a condition of demutualization
in states which do not require a closed block. The Maine
demutualization statute does not require a closed block. See ___
Me. Rev. Stat. Ann. tit. 24-A, 3477 (West 1996).

-12- 12













with an understanding that policy costs would be continually

adjusted through dividends reflecting Union Mutual's actual

experience. The Superintendent also noted that, when

purchasing their policies, policyholders based their dividend

expectations on dividend illustrations shown to them by Union

Mutual that were in turn based on the dividends the company

had been paying pursuant to the dividend scales current at

the time of purchase. The Superintendent concluded:

Even though these "illustrations" were
not guarantees that dividends would be
paid, Union Mutual, in practice,
typically paid dividends in accordance
with these scales. Based upon these
illustrations and upon actual practice,
policyholders expect that they will
continue to receive these dividends as
long as their policies are in force.
Therefore, I find it appropriate that the
Plan, by creating a mechanism such as the
PFA, supports these expectations of
future dividends.

That the PFA would maintain these expectations was, according

to the Superintendent, critical to the acceptability of the

conversion plan.

Union Mutual implemented its plan of conversion on

November 14, 1986. To the 105,098 Eligible Policyholders who

selected the Cash Option, Union Mutual distributed

$129,129,082. To the remaining 58,561 Eligible

Policyholders, Union Mutual distributed 20,489,072 shares of

UNUM stock. This stock was assessed as having a fair market

value of $25.20 per share, making the total value of the UNUM



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stock distributed under the Plan equal to $522,471,336.

Union Mutual also distributed an additional $609,396 in cash

to compensate policyholders for the value of fractional

shares created by the conversion formula. In total, Union

Mutual distributed $652,209,814 to the Eligible Policyholders

during the demutualization.

Prior to the demutualization, on October 12, 1984,

Union Mutual's tax counsel had asked the IRS for a private

letter ruling on the tax treatment of the conversion.

Contrary to the position taken by UNUM now, Union Mutual then

sought to convince the IRS that the stock distributed to

policyholders in exchange for their membership interests in

Union Mutual would constitute tax free exchanges under 351

of the Code. UNUM also sought to persuade the IRS that the

exchange of the membership interests received by the holding

company for common stock of the new stock company would

constitute a tax free recapitalization under 368(a)(1)(E).

In support of these positions, Union Mutual made a

submission to the IRS on March 25, 1985 stating that "the

equity interest of Union Mutual's policyholders resemble the

rights of stockholders in a corporation and have substantial

value." The submission further stated that the Supreme

Court, in Helvering v. Southwest Consolidated Group, 315 U.S. _________________________________________

194 (1942), had characterized a recapitalization as a

"reshuffling of a capital structure within the framework of



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an existing corporation," Id. at 202, and argued that "[t]he ___

exchange of evidences of ownership interest in Union Mutual _________

argues for the exchange being treated as a recapitalization"

under the Supreme Court's characterization. Id. (emphasis in ___

original).

Union Mutual made another submission to the IRS on

November 8, 1985, discussing whether the exchange of the

membership interests for cash or stock would be treated as

nondeductible redemptions of stock under 302 or as

deductible "policyholder dividends" under 808 and 805,

although UNUM did not specifically ask for a letter ruling on

that subject at that time.

On December 16, 1986, the IRS issued its private

letter ruling to Union Mutual regarding the proper tax

treatment of the demutualization. See Priv. Ltr. Rul. 87-11- ___

121 (December 16, 1996). The letter ruling stated that the

exchange between the policyholders and UNUM of the

policyholders' membership interests in Union Mutual for UNUM

stock was a tax-free exchange under 351. See id. The ___ ___

ruling also stated that the exchange between UNUM and UNUM

Life, the stock insurer that would succeed Union Mutual, of

the Union Mutual membership interests for UNUM Life voting

common stock was a tax free recapitalization under

368(a)(1)(E). See id. The ruling further stated that the ___ ___

cash distributed to policyholders in exchange for their



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membership interests constituted value-for-value transfers

and were, accordingly, properly characterized as

nondeductible redemptions under 302, not deductible

"policyholder dividends" under 808 and 805. See id.6 ___ ___

The IRS viewed the stock-for-membership interest exchanges,

in contrast, as non-recognition exchanges subject to 351

(no gain or loss recognized to policyholders), 354 (no gain

or loss recognized to holding company on exchange of

membership interests to converted company for stock, and

1032 (no gain or loss recognized to either holding company or

converted company on receipt of property for stock).

On its 1986 consolidated federal income tax return,

UNUM did not claim a "policyholder dividend" deduction for

the cash and stock distributed to policyholders during the

demutualization. UNUM had entered into an agreement with the

IRS extending the time period within which the IRS could

audit the 1986 return, after which UNUM would be given an

____________________

6. The IRS has not always held this view regarding the tax
treatment of distributions from surplus made during a
demutualization. In 1983, the IRS issued a non-binding
technical advice memorandum addressing the demutualization of
a mutual casualty insurer through merger with a stock
insurer. Tech. Adv. Mem. 8409003 (Nov. 4, 1983). In this
memorandum, the IRS took the view now advanced by UNUM that
cash distributions paid out of surplus to policyholders
during the demutualization were policyholder dividends under
then 822(e)(2) and 822(c)(11). In 1989, the IRS withdrew
this memorandum without comment. Tech. Adv. Mem. 9010003
(Nov. 13, 1989). Because such memoranda are nonbinding, we
do not base our conclusions upon them. We nonetheless
recognize that the IRS has not consistently maintained the
positions it presently advances in this appeal.

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additional six months within which to decide whether to amend

the return to claim a refund. The IRS audit, which ended in

1991, concluded that UNUM had properly characterized the cash

distributions as nondeductible stock redemptions under 302

and the stock distributions as made pursuant to

nonrecognition exchanges of its stock for property. UNUM

thereafter changed its view of the proper tax treatment of

the transaction by timely amending its 1986 return to claim

the cash ($129,738,478), then the value of the stock

($522,471,336), as deductible policyholder dividends under

808 and 805. UNUM sought a refund in excess of $77

million. The IRS denied these claimed deductions.

In 1993, UNUM filed suit in the district court,

seeking deductions and a refund of the $77 million. The

district court ruled in favor of the government, holding that

the cash and stock distributions could not be construed as

"policyholder dividends" under 808. UNUM appeals.

II II

UNUM makes a colorable but ultimately unpersuasive

argument that this appeal involves only the narrow task of

interpreting 808 and 805 of the Code. UNUM would have at

least a plausible argument that it was entitled to a

"policyholder dividend" deduction if those two sections were

the only potentially relevant Code sections to this case.

But we must construe the Code as a whole. The Supreme Court



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admonished in Helvering v. N.Y. Trust Co., 292 U.S. 455 _________ ________________

(1934), that "the expounding of a statutory provision

strictly according to the letter without regard to other

parts of the Act and legislative history [may] often defeat

the object intended to be accomplished." Id. at 464. ___

Therefore, courts must

not look merely to a particular clause in
which general words may be used, but . .
. take in connection with it the whole
statute (or statutes on the same subject)
and the objects and policy of the law, as
indicated by its various provisions, and
give to it such a construction as will
carry into execution the will of the
Legislature, as thus ascertained,
according to its true intent and meaning.

Id. (citation and internal quotations omitted). ___

We conclude that 808 and 805 do not govern this

case. UNUM's demutualization constitutes a capital

transaction and is accordingly subject to the general

corporate tax rules under Subchapter C which govern such

transactions. These rules clearly bar any deduction for

amounts distributed during a capital transaction.

A. Structural Overview ___________________

Because this case involves the interplay between

two Subchapters of the Code, we describe them in general

terms. Subchapter C is a broadly applicable section of the

Code which contains many of the Code's general corporate tax

provisions. It applies to all corporations, including mutual

and stock insurance companies. See 7701(a)(3) ("When used ___


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in this title, . . . [t]he term 'corporation' includes . . .

insurance companies."); 7701(a)(8) ("the term 'shareholder'

includes a member in an . . . insurance company.").

Subchapter C governs corporate capital transactions

and the taxation of all corporate distributions and

adjustments, including the organization, operation,

liquidation, and reorganization of all corporate enterprises

and their distributions to shareholders and associates. See ___

301-85. Many general rules in Subchapter C as well as

additional rules in other sections of the Code contain

language that, by their literal terms, bar the deduction UNUM

seeks. Sections 162, 311, 354, and 1032 apply with

particular force. We explain these sections and discuss why

they apply later.

Subchapter L, in contrast, is a highly focused

section of the Code which specifically governs certain

aspects of the taxation of life insurance companies. See ___

801-818. Subchapter L enacts a special scheme of

determining the gross income, deductions, and taxable income

of life insurance companies, whether of the stock or mutual

variety. It accommodates the unique manner by which life

insurance companies raise and distribute capital. One

purpose behind this parallel system of income calculation is

to determine more accurately the taxable income of life





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insurance companies than general tax rules otherwise would

permit.

While Subchapter L applies specifically to life

insurance companies, the existence of Subchapter L does not

exempt insurance companies from the application of the rest

of the Code. Subchapter L at times specifically displaces

otherwise applicable rules. For example, life insurance

company taxable income is defined in 801 as "life insurance

gross income" reduced by "life insurance deductions".

801(b). "Life insurance gross income" is specifically

defined in 803, not the generally applicable definition of

gross income provided in 61. And "life insurance

deductions" are specifically governed by 804 and 805,

even though 804 and 805 incorporate many of the general

rules about deductions by reference. But Subchapter L does

not alter general tax rules governing subjects not within its

ambit. Specifically, Subchapter L does not exempt insurance

companies from the general corporate tax rules of Subchapter

C "[e]xcept to the extent that [Subchapter L makes] specific

provisions." S. Rep. No. 291, 86th Cong., 1st Sess. 39

(1959), reprinted in 1959-2 C.B. 770, 798. ____________

The Supreme Court addressed the relationship

between Subchapter C and Subchapter L in Colonial American _________________

Life Ins. Co. v. Commissioner, 491 U.S. 244 (1989). Colonial _____________ ____________ ________

American involved the question of whether "ceding ________



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commissions" paid by a reinsurance company to a direct

insurer under an indemnity reinsurance contract could be

deducted in the year in which they were paid, or whether they

had to be capitalized over the estimated life of the

underlying policies. See id. at 246-47. The taxpayer argued ___ ___

that the ceding commissions were analogous to certain agents'

commissions deductible under 809 and should be similarly

deductible. See id. at 249-50. The IRS responded that the ___ ___

ceding commissions were more properly characterized as a type

of capital expenditure and should, as is usual for such

expenditures, be amortized over their useful life under

263. See id. at 252-53. The Court ruled against the ___ ___

taxpayer, holding that 809 did not expressly provide for

the requested deduction and that 263 should apply in the

absence of a specific provision to the contrary. See id. at ___ ___

260. The taxpayer's argument, the Court stated,

at most proves only that Congress decided
to carve out an exception for agents'
commissions, notwithstanding their
arguable character as capital
expenditures. We would not take it upon
ourselves to extend that exception to
other capital expenditures,
notwithstanding firmly established tax
principles requiring capitalization,
where Congress has not provided for the
extension.

Id. at 252. ___

Under the rule of Colonial American, general __________________

corporate tax provisions of Subchapter C apply to insurance



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companies unless Subchapter L makes a specific provision to

the contrary. The question that this case poses, therefore,

is whether the cash and stock distributions made by UNUM

during its conversion are made specifically deductible by

808 and 805 of Subchapter L, notwithstanding the fact

that they are clearly not deductible under 162, 311,

354, 1032 and other relevant provisions of the Code.

B. UNUM's burden of proof ______________________

It is a now "familiar rule" that an income tax

deduction "'is a matter of legislative grace and that the

burden of clearly showing the right to the claimed deduction

is on the taxpayer.'" INDOPCO, Inc. v. Commissioner, 503 ______________ ____________

U.S. 79, 84 (1992) (quoting Interstate Transit Lines v. __________________________

Commissioner, 319 U.S. 590, 593 (1943)). Deductions must ____________

therefore be "strictly construed" and allowed "'only as there

is clear provision therefor.'" Id. (quoting New Colonial Ice ___ ________________

Co. v. Helvering, 292 U.S. 435, 440 (1934)). Subchapter L ___ _________

has been subject to narrow construction because its

provisions "give life insurance companies tax benefits over

other taxpayers." National Life & Accident Ins. Co. v. ____________________________________

United States, 385 F.2d 832, 833 (6th Cir. 1967). Thus it is _____________

UNUM's burden to demonstrate that the cash and stock

distributed during the demutualization constitute deductible

"policyholder dividends" under 808.

C. Analysis of UNUM's arguments ____________________________



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UNUM's principal argument is that the cash and

stock distributions constitute "policyholder dividends" under

the plain meaning of 808, 808(b)(1) in particular, and

are therefore deductible under 805(a)(3). Bolstering this

position are two overlapping contentions: (1) the

legislative history and public policy underlying the Code's

scheme of life insurance taxation demonstrate that Congress

intended the term "policyholder dividend" to include the

distributions made during UNUM's demutualization; and (2)

because "policyholder dividends" are broader than classic

corporate dividends, "policyholder dividends" need not

possess the essential characteristics of a dividend -- i.e.,

they are not subject to the constraints which limit the

classic definition of dividends. We reject both arguments.

There is no dispute that 805(a)(3) allows life

insurance companies to deduct "policyholder dividends" from

income. Section 805(a)(3) expressly states: "there shall be

allowed the following deductions: . . . --The deduction for

policyholder dividends. . . ." 805(a)(3). The real

question, rather, is whether the definition of "policyholder

dividend" in 808 encompasses the cash and stock distributed

during UNUM's demutualization.

In this regard, UNUM's principal argument is that

the plain meaning of 808 entitles it to deduct the amounts





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distributed during the demutualization.7 We believe that, in

order to make this claim successfully, UNUM must demonstrate

that the distributions satisfy both 808(a) and 808(b).

Section 808(a) provides that:

[F]or purposes of this part, the term
"policyholder dividend" means any
dividend or similar distribution to
policyholders in their capacity as such.

808(a). Under 808(b)(1), upon which UNUM hinges the main

body of its argument, a "policyholder dividend" may include:

any amount paid or credited (including as
an increase in benefits) where the amount
is not fixed in the contract but depends
on the experience of the company or the
discretion of the management.

808(b).

UNUM asserts that the distributions easily satisfy

808(a), which, UNUM claims, merely emphasizes the broad

scope of "policyholder dividends." The source of UNUM's

authority for this claim is unclear. UNUM seems to rely


____________________

7. Section 808(a) and (b) provide in full:

(a) Policyholder dividend defined.--for purposes of this
part, the term "policyholder dividend" means any dividend or
similar distribution to policyholders in their capacity as
such.
(b) Certain amounts included.--For purposes of this
part, the term "policyholder dividend" includes--
(1) any amount paid or credited (including as an
increase in benefits) where the amount is not fixed
in the contract but depends on the experience of
the company or the discretion of the management.
(2) excess interest,
(3) premium adjustments, and
(4) experience-rated refunds.

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principally on Republic Nat'l Life Ins. Co. v. United States, ____________________________ _____________

594 F.2d 530 (5th Cir. 1979), in which the court stated that

"policyholder dividends" have an "expansive definition" and

"include more than just classic dividends." Id. at 532. ___

UNUM seems also to rely on Treas. Reg. 1.811-2(a) (1997),

which tracks the language of 808(a), as further evidence of

the broad scope of the "policyholder dividend." Because

"policyholder dividends" are "expansive", UNUM argues, they

necessarily encompass the amounts distributed during the

demutualization. We are not persuaded by these arguments,

which attempt to sweep the language of 808(a) under the

table. Rather, we think that 808(a) presents a major

obstacle, which UNUM fails to overcome.

UNUM argues that the real test is whether the

distributions satisfy 808(b). UNUM focuses its attention

on the text of 808(b)(1), arguing: (1) Nothing in the

insurance contracts between UNUM and its policyholders

addressed the amounts due to the policyholders in a

demutualization; therefore the amounts were "not fixed in the

contract"; (2) The cash was distributed out of Union Mutual's

accumulated surplus, which represents the fruits of the

company's considerable business success since its founding;

therefore the amounts "depend[ed] on the experience of the

company"; (3) Union Mutual's management, though subject to

the supervision of the Maine Superintendent of Insurance and



-25- 25













obligated to present "fair and equitable" terms to the

policyholder, decided the amounts within that range which

would be paid to policyholders in exchange for their equity

interests; therefore, the amounts were based "on the

discretion of management." The combination of these

circumstances, UNUM argues, satisfies the elements of

808(b)(1), and thus the distributions are "policyholder

dividends" deductible under 805(a)(3), regardless of the

general corporate tax provisions contained in Subchapter C.

While we recognize that UNUM's argument is

plausible, we nonetheless find it unpersuasive. As we

explain later, 808(b) describes categories of distributions

that may constitute policyholder dividends provided that the

definition of 808(a) is met. But UNUM has failed to

satisfy us that the term "policyholder dividend" under

808(a) includes value-for-value exchanges that occur during

a corporate reorganization such as this. UNUM's argument

ultimately suffers from a fundamental defect: it assumes that

Congress wished to ignore the context in which the cash and

stock distributions took place. We later explain why UNUM's

arguments that the distributions fit within 808(a) fail.

We first set the stage as to why Subchapter C applies.

D. Application of Subchapter C ___________________________

In a paradigmatic recapitalization, the corporation

is not allowed a deduction for distributions made in the



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course of the transaction. See Woodward v. Commissioner, 397 ___ ________ ____________

U.S. 572, 579 n.8 (1970) ("[W]herever a capital asset is

transferred to a new owner in exchange for value either

agreed upon or determined by law to be a fair quid pro quo,

the payment itself is a capital expenditure . . ."); United ______

States v. Houston Pipeline Co., 37 F.3d 224, 226 (5th Cir. ______ ____________________

1994) ("Stock redemptions, as a general rule, are

characterized as capital transactions, and the purchase price

of a stock redemption is not deductible.") (footnotes