- 24 -
year are reasonable. In General Signal Corp. & Subs. v.
Commissioner, supra, we found that the taxpayer's calculations
were not reasonable where the estimates were not made as of the
fund's yearend, the computations did not apportion administrative
costs between insurance premiums and other qualified direct
costs, and the calculations were made using direct costs from the
wrong years. If there were no reasonableness standard, taxpayers
would automatically be entitled to the safe harbor limits. The
legislative history, however, states that "Even if the safe
harbors are satisfied, the taxpayer is to show that the reserves,
as allowed under the general standards provided by the bill
(e.g., claims incurred by unpaid) are reasonable." General
Signal Corp. & Subs. v. Commissioner, supra at 232 (quoting H.
Conf. Rept. 98-861, at 1158 (1984), 1984-3 C.B. (Vol. 2) 1, 412).
In General Signal, we addressed and rejected much of the
argument petitioner makes in the instant case. Petitioner
neither cites nor addresses the analysis provided in General
Signal. Our reasoning in General Signal is supported by the
legislative history, and, because petitioner has neither argued
that the additions to the account limit based on the safe harbors
are reasonable nor offered a compelling argument to abandon the
General Signal reasoning in the instant case, we will not do so.
Consequently, we grant respondent's motion for partial summary
judgment with regard to the CIBU's, and deny petitioner's motion
for partial summary judgment with regard thereto. In so doing,
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