- 80 - 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 totalPage: Previous 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 Next
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