Atlantic Mutual Insurance Company and Includible Subsidiaries - Page 9

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          $125 million at the end of 1987.  But for section 846, the losses           
          incurred deduction attributable to unpaid losses would have been            
          $25 million (i.e., $125 million - $100 million).  If pursuant to            
          section 846 the $125 million of reserves at the end of 1987 were            
          discounted to $110 million, the P&C insurer's losses incurred               
          deduction would have been reduced from $25 million to $10 million           
          (i.e., $110 million - $100 million).                                        
               To address this problem, Congress included a transition rule           
          in TRA '86.  The transition rule provided that, for purposes of             
          computing the losses incurred deduction at yearend 1987, 1986               
          reserves also would be discounted.  TRA '86 sec. 1023(e)(2), 100            
          Stat. 2404.  As a result of this transition rule, discounted 1987           
          reserves were compared with discounted 1986 reserves in computing           
          the losses incurred deduction for the 1987 taxable year.                    
               B.  The Application of Section 481                                     
               Even with the transition rule described above, P&C insurance           
          companies remained subject to adverse tax consequences due to the           
          application of section 481.  When a taxpayer changes its method             
          of accounting, section 481 generally requires that the taxpayer             
          make adjustments to prevent amounts from being duplicated in or             
          omitted from its taxable income.  Compliance with the requirement           
          that P&C insurers change the basis for computing their losses               
          incurred deductions from an undiscounted to a discounted                    
          methodology constituted a change in accounting method.  Thus,               
          section 481 would have required P&C insurers to recognize as                




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