පතිනියකගේ හොරාව (2 කොටස) http://www.mediafire.com/view/?iszpp7l1ouj3dx5
A casualty insurance company provided $30x coverage to an insured in Revenue Ruling 89-96.181 The insured incurred a liability of an unascertained amount as a result of a catastrophe in June 1987 although the underlying facts indicated that the total liability would exceed $130x. The insured subsequently paid $50x to obtain $100x of additional insurance, increasing the coverage for the catastrophe to $130x. The insurer increased its unpaid losses by $100x and deducted the (discounted) present value of the $100x increase in coverage as losses incurred.
The Service ruled that the retroactive arrangement did not qualify as insurance. Risk-shifting was lacking because the catastrophe covered by the contract already occurred. The Service stated that establishing a loss for $100x indicated that the insurer expected to have to pay the additional $100x of coverage. The taxpayer incurred the risk that payments on the contract would be made earlier than expected and that the investment yield for the period from the date that the premium was received until the date the claim was paid would be less than expected, which are investment risks
