- 40 - under petitioner’s existing name. Under this reinsurance model used by petitioner’s expert, petitioner’s 23,526 group contracts effectively were valued together as a mass and not as distinct assets separate from each other and from petitioner’s other intangible assets. In his valuation, petitioner’s expert utilized incomplete information and either ignored, improperly applied, or made incorrect assumptions about unique characteristics associated with petitioner’s group contracts. In his analysis of the life of petitioner’s health insurance group contracts, petitioner’s expert incorrectly assumed a 20- year useful life for all of petitioner’s separate health insurance group contracts, and he incorrectly assumed that lapse rates for the group contracts would be consistent with certain outdated information. We explain further the key aspects of petitioner’s expert’s valuation of the group contracts with which we disagree.12 Reinsurance Model The reinsurance model used by petitioner’s expert values petitioner’s 376 group contracts that were terminated in 1994 and 12 In the instant case, because petitioner went to some significant effort to cure the item by item valuation deficiencies that the District Court detailed in its opinion in Trigon Ins. Co. v. United States, 215 F. Supp. 2d 687 (E.D. Va. 2002), supplemented at 234 F. Supp. 2d 581 (E.D. Va. 2002), our criticisms of petitioner’s valuation of the group contracts are more general than those of the District Court in Trigon Ins. Co., but they are equally fatal to petitioner’s claimed loss deductions.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011