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WESTERN NATL. MUT. INS. CO. v. COMMISSIONER

Docket No. 11620-91.

102 T.C. 338 (1994)

WESTERN NATIONAL MUTUAL INSURANCE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 28, 1994.

Attorney(s) appearing for the Case

Jay B. Kelly, E.P. Baker, and Peter H. Winslow, for petitioner.

J. Anthony Hoefer, for respondent.

GERBER, Judge:

Respondent determined an $89,366 Federal income tax deficiency for petitioner's 1987 taxable year. The issue remaining in controversy is whether petitioner engaged in reserve strengthening within the meaning of section 1023(e)(3)(B) of the Tax Reform Act of 1986 (TRA 86), Pub. L. 99-514, 100 Stat. 2404. In that context, we consider whether section 1.846-3(c), Income Tax Regs., is valid and more specifically whether the definition of reserve strengthening...

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