-21- that KPMG Peat Marwick erred in not recommending that Crossroads discount its reserves for 1991 and 1992 for the time value of money as it had recommended that Crossroads do for 1989 and 1990. We disagree that KPMG Peat Marwick should have considered the time value of money in estimating Crossroads' reserves. First, respondent points out that, as of December 31, 1995, and without considering the time value of money, KPMG Peat Marwick's estimate of Crossroads' reserves for 1991 and 1992 had been shown to be almost 100 percent accurate compared to Crossroads' known claim losses for those years. Second, Wise did not reduce Crossroads' reserves based on time value of money principles, nor did we reduce the reserves in Estate of Feldmar v. Commissioner, supra, to account for the time value of money. Third, respondent's contention that section 846 requires reinsurance companies to discount their unpaid losses (or reserves) to take into account the time value of money misses the mark. We are not computing Crossroads' reserve for unpaid losses for income tax purposes; we are valuing the stock of Crossroads. Respondent used KPMG Peat Marwick's reserve estimates and valuation method as a benchmark to discredit Gallagher's report, and made no convincing argument that we should not adopt KPMG Peat Marwick's conclusion. We conclude that KPMG Peat Marwick's conclusions were reasonable.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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