- 24 - 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.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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