Hospital Corporation of America and Subsidiaries - Page 93

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               In his report, Mr. Merlino recommends adjustments to                   
          Parthenon's workers' compensation unpaid losses reserves and                
          professional and general liabilities reserves to conform those              
          reserves to the amounts recommended by Mr. Biscoglia.  Respondent           
          has adopted Mr. Merlino's position to support the Government's              
          position.  We deem that action to be a concession by respondent             
          that the values recommended by Mr. Biscoglia for the unpaid                 
          losses reserves for workers' compensation and professional and              
          general liabilities are a fair and reasonable estimate of                   
          Parthenon's actual unpaid losses for those lines of business for            
          years ended 1987 and 1988.  In his report Mr. Merlino proposes no           
          adjustment to the unpaid losses reserves for other lines of                 
          business carried by Parthenon for years ended 1987 and 1988.  We            
          deem that inaction as a concession by respondent that the                   
          reserves for those lines of business are a fair and reasonable              
          estimate of Parthenon's actual unpaid losses for those lines of             
          business for those years.  We conclude that Parthenon is entitled           
          to deduct additions to its reserves for the years in issue in               
          amounts to be calculated by the parties in accordance with their            
          stipulations and the foregoing.                                             
               Additionally, respondent contends that petitioners have                
          failed to substantiate their claims regarding the reserves in               








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