Atlantic Mutual Insurance Company and Includible Subsidiaries - Page 10

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          income the difference between (1) the undiscounted amount of loss           
          reserves, as of yearend 1986, included in the computation of the            
          losses incurred deduction for 1986 and (2) the discounted amount            
          of such loss reserves.                                                      
               To avoid triggering section 481 adjustments, Congress                  
          provided P&C insurers with a "fresh start" pursuant to section              
          1023(e)(3) of TRA '86.  TRA '86 sec. 1023(e)(3)(A), 100 Stat.               
          2404.  This section provides as follows:                                    
               (3) Fresh start.--                                                     
                    (A)  In general.--Except as otherwise provided in                 
               this paragraph, any difference between--                               
                         (i) the amount determined to be the unpaid                   
               losses and expenses unpaid for the year preceding the                  
               1st taxable year of an insurance company beginning                     
               after December 31, 1986, determined without regard to                  
               paragraph (2) [i.e., without discounting], and                         
                         (ii) such amount determined with regard to                   
               paragraph (2) [i.e., with discounting],                                
               shall not be taken into account for purposes of the Internal           
               Revenue Code of 1986.                                                  
          In essence, the fresh start provision overrode section 481 by               
          excluding from taxable income the difference between the amount             
          of the yearend 1986 undiscounted loss reserves and the discounted           
          amount of such reserves.  In its report, the Committee of                   
          Conference (conference committee) described the effect of the               
          fresh start provision as a "forgiveness of income".  H. Conf.               
          Rept. 99-841 (Vol. II), at II-367 (1986), 1986-3 C.B. (Vol. 4) 1,           
          367.                                                                        





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