Charles C. Dockery, Donor - Page 21

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          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.                                                








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