Atlantic Mutual Insurance Company and Includible Subsidiaries - Page 12

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          contained in both the Senate bill and in the accompanying Senate            
          Finance Committee report.                                                   
               The Senate bill contained the following provision:                     
                    (B) Reserve Strengthening After March 1, 1986.--                  
               * * * [the fresh start provision] shall not apply to                   
               any reserve strengthening reported for Federal income                  
               tax purposes after March 1, 1986, for a taxable year                   
               beginning before January 1, 1987, and such                             
               strengthening shall be treated as occurring in the                     
               taxpayer's 1st taxable year beginning after December                   
               31, 1986.  The preceding sentence shall not apply to                   
               the computation of reserves on any contract if such                    
               computation employs the reserve practice used for                      
               purposes of the most recent annual statement filed on                  
               or before March 1, 1986, for the type of contract with                 
               respect to which such reserves are set up.  [H.R. 3838,                
               99th Cong., 2d Sess., sec. 1022(e)(3)(B), as reported                  
               by the Senate Finance Committee on May 29, 1986.]                      
               The Finance Committee report stated that "reserve                      
          strengthening" consisted of "any adjustments to reserves that are           
          attributable to changes in reserves on account of changes in the            
          basis for computing reserves (i.e., reserve strengthening or                
          reserve weakening) in a taxable year beginning before January 1,            
          1987".  S. Rept. 99-313, supra at 510, 1986-3 C.B. (Vol. 3) at              
          510.                                                                        
               The differences between the House and Senate versions of               
          H.R. 3838 were reconciled by the conference committee.  The final           
          bill adopted by the conference committee and enacted into law did           
          not define "reserve strengthening".  It provided as follows:                
                    (B) Reserve Strengthening In Years After 1985.--                  
               * * * [the fresh start provision] shall not apply to                   
               any reserve strengthening in a taxable year beginning                  
               in 1986, and such strengthening shall be treated as                    
               occurring in the taxpayer's 1st taxable year beginning                 




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