Hospital Corporation of America and Subsidiaries - Page 80

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          Rather, unpaid losses must be based on the actual loss experience           
          of the insurance company.  See Maryland Deposit Ins. Fund Corp.             
          v. Commissioner, 88 T.C. 1050, 1060 (1987); Modern Home Life Ins.           
          Co. v. Commissioner, 54 T.C. 935, 939-940 (1970).  The taxpayer             
          has the burden to establish "to the satisfaction of the district            
          director" that the unpaid losses comprise actual unpaid losses.             
          Sec. 1.832-4(b), Income Tax Regs.; see also Hanover Ins. Co. v.             
          Commissioner, supra.                                                        
               Based on Mr. Merlino's calculations, respondent contends               
          that, when established, the unpaid loss reserves claimed by                 
          Parthenon for years ended 1984, 1986, 1987, and 1988 were not               
          reasonable based on acceptable actuarial methods within the                 
          meaning of section 832(b)(5).  Respondent contends that                     
          Parthenon's professional and general liability reserves should be           
          increased for year ended 1984 by $16,177,587 and decreased for              
          years ended 1986, 1987, and 1988 by $67,384,000, $14,978,000, and           
          $29,058,000, respectively.  Additionally, respondent contends               
          that Parthenon's workers' compensation liability reserve should             
          be increased for years ended 1984, 1987, and 1988 by $6,098,709,            
          $4,131,000, and $3,616,000, respectively.  Accordingly,                     
          respondent contends that net adjustments to Parthenon's total               










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