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ATLANTIC MUT. INS. CO. v. COMMISSIONER

No. 97-147.

523 U.S. 382 (1998)

ATLANTIC MUTUAL INSURANCE CO. v. COMMISSIONER OF INTERNAL REVENUE

United States Supreme Court.

Decided April 21, 1998.

Attorney(s) appearing for the Case

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.*

Scalia, J., delivered the opinion for a unanimous Court.

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 reserves, or only increases that result...

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