§8074

ner, a life insurance company,i improperly computed its tax reserves for certain reinsurance treaties 2 Respondenthas since conceded that there is no deficiency, and the parties stipulated that respondent accepts petitioner's tax reserve computations.3 The parties still dispute as a matter oflaw whetherpetitioner may compute its tax reserves under section 8074 by using a reserve method adopted after the treaties were executed (tax reserve issue).