-33- reserves for certain lines “in which the reserves otherwise computed have historically proven inadequate.” The Commissioner had argued that the voluntary loss reserves were greater than historical deficiencies in the schedule P lines of coverage and were intended to cover deficiencies in certain schedule O lines of coverage. Rejecting the Commissioner’s arguments, we held that the test of reasonableness should be directed at the total unpaid loss reserves rather than at individual lines of coverage, and that the taxpayer’s total estimated reserves were not only reasonable but actually understated in light of prior experience. See id. at 919-920. In the instant case, by contrast, petitioner has not shown that, for the years in issue, it established adverse development reserves to ensure the adequacy of reserves that historical experience had proved inadequate, or that its total reserves are reasonable in light of prior experience. To the contrary, the evidence strongly suggests that for each year in issue, petitioner’s recent historical experience had proved petitioner’s case reserves to be generous. For example, petitioner’s own reserve analyses for the years in issue indicate significant redundancies in its case reserves. Petitioner’s appointed actuary noted that as of yearend 1993, there was total “redundancy” in petitioner’s total booked net loss reserve of $4,210,000–-which exceeds the $3,155,000 adverse development reserve that petitioner established for 1993. ThePage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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