-32- losses for coverage years 1987 through 1992, reestimated at the end of 1996. Respondent's argument misses the mark. Although we agree that Kilbourne's method is reasonable, we need not decide whether his method is more reasonable than petitioner's method. Section 1.832-4(b), Income Tax Regs., requires that the taxpayer show that its unpaid losses were actual unpaid losses and that its estimate of loss reserves be fair and reasonable. Petitioner has satisfied the requirements of the regulations, and thus our inquiry ends. Cf. Molsen v. Commissioner, 85 T.C. 485, 498 (1985); Peninsula Steel Prods. & Equip. Co. v. Commissioner, 78 T.C. 1029, 1045 (1982) (the Commissioner cannot require a taxpayer to change from an accounting method which clearly reflects income to an alternate method merely because the Commissioner concludes that the alternate method more clearly reflects the taxpayer's income). 8. Whether Gleeson Confirmed That Hurley's Ranges Were Not Actuarially Sound Respondent argues that Gleeson confirmed Kilbourne's conclusion that Hurley's ranges were not actuarially sound.23 We disagree. Gleeson applied a probability distribution test to 23 Kilbourne said that Hurley's approach ignored the point estimate results of his four actuarial methods and that his ranges were skewed so that even the low ends of his ranges as of the end of 1991 and 1992 were higher than what in Kilbourne's opinion were actuarially reasonable "best estimates" of petitioner's ultimate losses.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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