-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 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011