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PHYSICIANS INSURANCE COMPANY OF WISCONSIN, INC. AND SUBSIDIARIES v. COMMISSIONER

Docket No. 3192-99.

82 T.C.M. 918 (2001)

T.C. Memo. 2001-304

Physicians Insurance Company of Wisconsin, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed November 21, 2001.

Attorney(s) appearing for the Case

Michael R. Schlessinger, Michael A. Clark, Jason K. Francl, Jay H. Zimbler, and William M. Sneed (specially recognized), for the petitioner. Avery B. Cousins III and J. Paul Knap, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes as follows:

     Year                       Deficiency

     1993...................... $8,209,201
     1994......................  1,293,762

After concessions, the sole issue for decision is the amount of unpaid losses and loss adjustment expenses (collectively, unpaid losses) that petitioner...

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