Cite as: 523 U. S. 382 (1998)
Opinion of the Court
reserve increases attributable to changes in methods or assumptions. Since the term is ambiguous, the question is not whether the Treasury Regulation represents the best interpretation of the statute, but whether it represents a reasonable one. See Cottage Savings Assn. v. Commissioner, 499 U. S. 554, 560-561. As a purely linguistic matter, the phrase is broad enough to embrace all increases in the reserve's amount, for whatever reason and from whatever source. The provision at issue is a limitation upon an extraordinary deduction accorded to PC insurers. There was no need for the deduction to be microscopically fair, and the interpretation adopted in the Treasury Regulation seems to be a reasonable accommodation of the competing interests of fairness, administrability, and avoidance of abuse. Given the hundreds (or more likely thousands) of claims involved, claims resolved for less than estimated reserves will tend to offset claims that settle for more than estimated reserves. Any discrepancy would not approach the unrealistic proportions claimed by Atlantic. Pp. 387-391.
111 F. 3d 1056, affirmed.
Scalia, J., delivered the opinion for a unanimous Court.
George R. Abramowitz argued the cause for petitioner. With him on the briefs were Dennis L. Allen, M. Kristan Rizzolo, John S. Breckinridge, Jr., and James H. Kenworthy.
Kent L. Jones argued the cause for respondent. With him on the brief were Solicitor General Waxman, Assistant Attorney General Argrett, Deputy Solicitor General Wallace, David I. Pincus, and Edward T. Perelmuter.*
Justice Scalia delivered the opinion of the Court.
Property and casualty insurance companies maintain accounting reserves for "unpaid losses." Under the Tax Reform Act of 1986, increases in loss reserves that constitute "reserve strengthening" do not qualify for a certain one-time tax benefit. We must decide whether the term "reserve strengthening" reasonably encompasses any increase in re*Briefs of amici curiae urging reversal were filed for Ambase Corp. by Peter H. Winslow and Gregory K. Oyler; and for the American Insurance Association et al. by Matthew J. Zinn, J. Walker Johnson, Craig A. Berrington, Allan J. Stein, and Steven C. Elliott.
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