- 6 - accident years. Under the formula, petitioner's reserves at yearend 1985 were reduced by the claims and the LAE paid in 1986 with respect to those reserves. To the extent that, at yearend 1986, a reserve was greater than the amount determined under the formula, the excess was treated as a net increase to that reserve account (i.e., "reserve strengthening"). To the extent that, at yearend 1986, a reserve was less than the amount determined under the formula, the difference was treated as a net decrease to that reserve account (i.e., "reserve weakening"). Respondent determined that, at yearend 1986, petitioner's "reserve strengthening" totaled the following amounts: Reserve Strengthening Line of Business (Weakening) Auto liability ...................... ($10,559,423) Other liability ..................... (1,279,374) Workers' compensation ............... 4,691,659 Multiple peril ...................... 15,585,877 Schedule O1 (1985) .................. (3,870,000) Schedule O (pre-1985) ............... 1,984,000 Net total ........................ 6,552,739 1Schedule 0, a part of the annual statement filed with the National Association of Insurance Commissioners, contains combined loss data on several lines of insurance business with respect to which claims are filed and settled within a relatively short period. Respondent then discounted, pursuant to section 846, the amount determined as "reserve strengthening" in order to calculate the effect on petitioner's gross income.1 After 1For a discussion of sec. 846 and discounting generally, see sec. I.A., "The Change from Undiscounted to Discounted Reserve Accounting", in the Discussion section of this opinion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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