Doyal v. C. I. R

1 Citing case

  1. Time Ins. Co. v. Comm'r of Internal Revenue

    86 T.C. 298 (U.S.T.C. 1986)   Cited 6 times
    Rejecting respondent's definition of the term `unpaid losses' where such definition had not clearly been expressed by Congress in the Code, or by the Treasury in the regulations applicable thereto

    Other circuits have reached the same conclusion. See Doyal v. Commissioner, 616 F.2d 1191 (10th Cir. 1980); Oliver v. Commissioner, 364 F.2d 575 (8th Cir. 1966); Lehman v. Commissioner, 129 F.2d 288 (2d Cir. 1942). In view of the foregoing, it is apparent that petitioner in this case has the burden of proof and the burden of going forward with regard to the proper amount of its deduction for claim reserves.