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amount annuity apply Article attorney-in-fact basis beginning after December capital loss carryback carryover CCH Explanation Code Sec company taxable income computed contracts December 31 Declared obsolete defined in section determined distribution dividends received domestic corporation effectively connected election estate investment trust exceed exempt filed foreign corporation foreign country gross income income from sources income tax insurance company taxable insurance reserves Internal Revenue Code Internal Revenue Service investment yield liability loss from operations mutual insurance mutual insurance company nonresident alien individual obsolete by Rev operations loss paragraph payment percent premiums provided by section real estate investment real property regulated investment company reinsured resident respect section 821 shareholders subparagraph taken into account tax imposed tax treaty taxable investment income taxable years beginning taxpayer tion trade or business treated U. S. sources underwriting unit investment trust United United Kingdom USTC withholding