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ATLANTIC MUTUAL INSURANCE COMPANY v. COMMISSIONER

Docket No. 25767-93.

71 T.C.M. 2154 (1996)

T.C. Memo. 1996-75

Atlantic Mutual Insurance Company and Includible Subsidiaries v. Commissioner.

United States Tax Court.

Filed February 22, 1996.

Attorney(s) appearing for the Case

John S. Breckinridge, Jr., and James H. Kenworthy, New York, N.Y., for the petitioners. Phillip A. Pillar and Maureen Nelson, for the respondent.

MEMORANDUM OPINION

FOLEY, Judge:

Respondent determined a deficiency of $519,987 in petitioners' Federal income tax for the 1987 taxable year as a result of alleged "reserve strengthening". Under the Tax Reform Act of 1986 (TRA `86), Pub. L. 99-514, sec. 1023, 100 Stat. 2085, 2404, any increases in the loss reserves maintained by property and casualty insurance companies that constitute "reserve strengthening" do not qualify for a one-time tax benefit. In...

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