Physicians Insurance Company of Wisconsin, Inc. and Subsidiaries - Page 24




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          T.C. 58, 78 (1971); Minn. Lawyers Mut. Ins. Co. v. Commissioner,            
          T.C. Memo. 2000-203.  This does not mean that there is (or could            
          be, except in hindsight) a single “correct” estimate.14  It does            
          mean, however, that the taxpayer must be prepared to objectively            
          validate that the methods and assumptions it relied upon to make            
          its estimate are reasonable.  See Minn. Lawyers Mut. Ins. Co. v.            
          Commissioner, supra (the taxpayer failed to establish the                   
          necessity or appropriateness of a bulk “adverse development                 
          reserve” that its management established as an addition to the              
          case reserves determined by its claim department); cf. Vinson &             
          Elkins v. Commissioner, 99 T.C. 9, 57 (1992) (in the context of             
          pension plan regulation, the section 412(c)(3) requirement that             
          actuarial estimates be reasonable and offer the actuary’s “best             
          estimate” of actuarial experience does not connote a single “best           
          estimate” but instead requires validation of actuarial                      
          assumptions in choosing a reasonable range and in selecting a               
          value within the range), affd. 7 F.3d 1235 (5th Cir. 1993).                 
          The Expert Witnesses                                                        
               Both parties called expert witnesses to offer their opinions           
          regarding the reasonableness of petitioner's unpaid loss                    
          estimates.  We evaluate expert opinions in light of all the                 



               14 For example, this Court has rejected an argument that the           
          midpoint of an actuarially sound range is the only fair and                 
          reasonable estimate.  See Utah Med. Ins. Association v.                     
          Commissioner, T.C. Memo. 1998-458.                                          





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