Atlantic Mutual Insurance Company and Includible Subsidiaries - Page 6

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          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.                     




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