MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioner had deficiencies in income tax of $5,280,264 for 1991 and $1,905,200 for 1992.
The sole issue for decision is whether petitioner may deduct $45,650,249 for its reserves for discounted unpaid losses and loss adjustment expenses for 1991 and $49,418,509 for 1992. We hold that it may.
Section references are to the Internal Revenue Code. Unless otherwise...
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