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decision to overstate petitioner’s reserves. At trial, however,
Otto conceded that he had no basis for this conclusion, except
that his actuarial analysis differed from Tillinghast’s.
We believe that Otto’s unsupported accusations and the
generally adversarial tone of the Kilbourne Co. report are more
indicative of advocacy than of the “detached neutrality” we
demand of expert witnesses. See Estate of Halas v. Commissioner,
94 T.C. 570, 577-579 (1990). The usefulness and credibility of
respondent’s experts are accordingly diminished, and we give
their opinions little weight in this regard. See, e.g., Buffalo
Tool & Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452
(1980); Anclote Psychiatric Ctr., Inc. v. Commissioner, T.C.
Memo. 1998-273; Podd v. Commissioner, T.C. Memo. 1998-231.
We are also unpersuaded by respondent’s contentions that
petitioner’s estimates of unpaid losses were unreasonable because
they proved, in hindsight, excessive. As this Court stated in
Utah Med. Ins. Association v. Commissioner, supra: “Petitioner’s
reserves for unpaid losses must be fair and reasonable, but are
not required to be accurate based on hindsight.” The evidence
shows that Tillinghast took into account developing redundancies
in establishing the estimates in question. Cf. Minnesota Lawyers
Mut. Ins. Co. v. Commissioner, T.C. Memo. 2000-203 (taxpayer
failed to show that it took prior favorable experience into
account in establishing adverse development reserves).
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