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.