-25- petitioner’s actual unpaid losses as nearly as they could be ascertained. On brief, respondent acknowledges that petitioner’s case reserves are “at least facially” in compliance with the regulatory requirement that unpaid losses be calculated “based on the facts in each case.” Sec. 1.832-4(b), Income Tax Regs. Respondent contends, however, that petitioner has failed to establish that the portion of its total unpaid loss reserves represented by its adverse development reserve was necessary or reasonable. III. Expert Witnesses The parties each called an expert witness to opine on the reasonableness of petitioner's reserves. We evaluate expert opinions in light of all the evidence in the record and may accept or reject the expert testimony, in whole or in part, according to our own judgment. See Helvering v. National Grocery Co., 304 U.S. 282, 295 (1938); Estate of Mellinger v. Commissioner, 112 T.C. 26, 39 (1999). A. Roger M. Hayne Petitioner’s expert, Roger M. Hayne (Hayne), is a consulting actuary in the firm of Milliman & Robertson, Inc.20 He is a member of the American Academy of Actuaries. He holds a 20 Although Milliman & Robertson, Inc., is the actuarial firm that provided the Witcraft opinion and report for petitioner’s 1993 year, there is no indication in the record that Roger M. Hayne (Hayne) was involved in the preparation of the Witcraft opinion or report.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011