- 22 - In Hanover, 65 T.C. at 719, this Court concluded that the applicable regulations were deemed to have received congressional approval and acquired the force of law by virtue of having been “long continued without substantial change, applying to unamended or substantially reenacted statutes”. This tacit congressional approval was made overt when, as part of the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1023(c), 100 Stat. 2085, 2399, Congress added section 846 (requiring that unpaid losses be discounted to reflect the time value of money for claims that would not be paid until future years). In explaining these changes, the conference report accompanying this legislation described prior law as follows: The amount of the deduction for losses incurred must be reasonable. See Reg. sec. 1.832-4(b) and Hanover Insurance Co. v. Commissioner, 598 F.2d 1121 (1st Cir. 1979), cert. denied, 444 U.S. 915. Thus, under present law, the Internal Revenue Service may review, and, if appropriate, adjust the amount of the deduction for unpaid losses and unpaid loss adjustment expenses. [H. Conf. Rept. 99-841 (Vol. II), at II-357 (1986), 1986-3 C.B. (Vol. 4) 1, 357.] Petitioner argues that various technical aspects of certain 1986 and 1990 Code amendments relating to P&C companies “continued, and in some ways strengthened, deference to the Annual Statement”. Without a protracted discussion of petitioner’s highly technical arguments in this regard, suffice it to say that we have reviewed them carefully and find them unpersuasive. Even if we were to assume, arguendo, that CongressPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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