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ATLANTIC MUT. INS. CO. v. C.I.R.

No. 96-7424.

111 F.3d 1056 (1997)

ATLANTIC MUTUAL INSURANCE COMPANY, and Includible Subsidiaries v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Third Circuit.

Decided April 24, 1997.

Attorney(s) appearing for the Case

John S. Breckinridge, Jr. (argued), James H. Kenworthy, LeBoeuf, Lamb, Greene & MacRae, New York City, Frederick B. Lacey, LeBeouf, Lamb, Greene & MacRae, Newark, NJ, for Appellee.

Gary R. Allen, David I. Pincus, Edward T. Perelmuter (argued), Loretta C. Argrett, Assistant Attorney General, United States Department of Justice, Tax Division, Washington, D.C., for Appellant.

Before: MANSMANN and LEWIS, Circuit Judges, and MICHEL, Circuit Judge.

OPINION OF THE COURT

MANSMANN, Circuit Judge.

In this appeal, we address the "fresh start" provision of section 1023(e)(3) of the Tax Reform Act of 1986. There Congress permitted property & casualty insurers a one-time forgiveness of income resulting from the change in computing "losses incurred deductions" from undiscounted to a discounted basis as mandated by newly enacted section 846 of the Internal Revenue Code. Specifically, the Commissioner challenges...

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