Section 812(e) provides that for purposes of part I, subchapter L, chapter 1 of the Code, a life insurance company is a ``new company'' for any taxable year only if such taxable year begins not more than 5 years after the first day on which it (or any predecessor if section 381(c)(22) applies or would have applied if in effect) was authorized to do business as an insurance company. [T.D. 7326, 39 FR 35354, Oct. 1, 1974]