- 7 - discounting the amounts shown in the foregoing chart, respondent determined that petitioner understated its 1987 income as follows: Line of Business Income Adjustment Auto liability ...................... ($1,211,842) Other liability ..................... (309,970) Workers' compensation ............... 1,211,652 Multiple peril ...................... 1,783,897 Schedule O (1985) ................... (239,446) Schedule O (pre-1985) ............... 104,748 Net total ........................ 1,339,039 Respondent further determined that this $1,339,039 understatement of petitioner's 1987 income resulted in a $519,987 understatement of petitioner's 1987 income tax liability. Discussion I. Overview TRA '86 substantially revised the rules that govern the taxation of P&C insurance companies by requiring P&C insurers to discount loss reserves for purposes of section 832(b)(5) (discussed below). The change from undiscounted to discounted methodology eliminated a tax benefit attributable to the time value of money. It also required taxpayers to change their accounting methods. To facilitate a smooth transition to the newPage: 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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