Minnesota Lawyers Mutual Insurance Company and Subsidiaries - Page 2

                  The sole issue for decision is what portion of petitioner’s                          
            reserves for unpaid losses and related loss adjustment expenses                            
            (unpaid loss reserves) should be included in its computation of                            
            “losses incurred” as defined in section 832(b)(5).                                         
                  Unless otherwise indicated, section references are to the                            
            Internal Revenue Code in effect for the taxable years in issue,                            
            and all Rule references are to the Tax Court Rules of Practice                             
            and Procedure.                                                                             
                                         FINDINGS OF FACT                                              
                  The parties have stipulated some of the facts, which are                             
            incorporated by this reference.                                                            
                  Petitioner, Minnesota Lawyers Mutual Insurance Co., was                              
            incorporated in Minnesota on May 28, 1981, as a mutual property                            
            and casualty insurance company.  Petitioner was formed after a                             
            task force of the Minnesota State Bar Association recommended the                          
            establishment of a self-insured program for professional                                   
            liability insurance for practicing lawyers in Minnesota.                                   
                  Before 1993, petitioner wrote exclusively professional                               
            liability insurance in Minnesota.  In 1993, petitioner began                               
            expanding its operations outside Minnesota and offering a                                  
            commercial multiple-peril policy.  Throughout its existence,                               
            however, petitioner has sold primarily professional liability                              
            insurance policies for lawyers.                                                            

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Last modified: May 25, 2011