United States Eighth Circuit

The Tax Court determines the fairness and reasonableness of unpaid loss estimates on a case-by-case basis, and need not defer to estimates set forth in an insurer's annual statement and accepted by a state insurance regulator if the taxpayer cannot otherwise defend its estimates with detailed information related to its own experience; no error in finding insurance company's estimate of unpaid loss reserves neither fair nor reasonable.

Appellate Information

• Decided 04/15/2002
• Published 04/15/2002

Judges

• BYE, Circuit Judge., Before MURPHY, BEAM and BYE, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Byron L. Frans, argued, Minneapolis, MN (John P. Borger, on the brief), for appellant.


• For Appellees:
  
• Steven W. Parks, Tax Division, Dept. of Justice, argued, Washington, DC (David I. Pincus, on the brief), for appellee.