- 36 - Commissioner, 88 T.C. at 1059. In sum, petitioner has failed to establish that its selection of unpaid loss estimates almost 10 percent greater than its actuary’s point estimates was based on reasonable methods or assumptions. Cf. Hospital Corp. of Am. v. Commissioner, T.C. Memo. 1997-482 (insurance company failed to establish the reasonableness of unpaid losses where it relied upon the extrapolation of a recommended range from fixed dollar values contained in its actuary’s reserve analysis reports). Accordingly, petitioner has failed to establish that its estimates of unpaid losses, insofar as they include the almost 10-percent add-ons to Tillinghast’s point estimates, are fair and reasonable within the meaning of the applicable regulations. Determination of Fair and Reasonable Estimates of Unpaid Losses Respondent’s experts’ estimates of petitioner’s unpaid losses differ in amount not only from Tillinghast’s point estimates but also (by a smaller margin) from respondent’s determinations in the statutory notice.23 Contending broadly 23 The unpaid loss estimates selected by Tillinghast, respondent (in the statutory notice), and respondent’s experts were as follows: Tillinghast Respondent’s Respondent’s Year Point Estimates Determinations Experts 1993 $74,027,009 $46,508,000 $50,000,000 1994 77,029,796 45,549,000 39,000,000Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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