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HOME MUTUAL INSURANCE CO. v. COMMISSIONER

Docket No. 6587-75.

70 T.C. 944 (1978)

HOME MUTUAL INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 18, 1978.

Attorney(s) appearing for the Case

Paul A. Pakalski and Michael T. Hart, for the petitioner.

Nelson E. Shafer, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined deficiencies in petitioner's Federal mutual insurance company income taxes for the taxable years 1966 and 1971 in the respective amounts of $29,906.21 and $18,624.50. The issues for decision are as follows:

(1) Should petitioner be permitted to adjust its estimate of unpaid losses as of December 31, 1962, in each of its subsequent taxable years based strictly upon settlements of its claims...

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