Legal Opinion

Charleston Nat'l Bank v. Commissioner

United States Tax Court

Decided April 30, 1953No. Docket No. 33231Published

1. For the taxable years 1944 and 1945, petitioner paid premiums on life insurance policies held as security for certain debts previously charged off to profit and loss in prior years. Held, deductible as ordinary and necessary business expenses. Dominion National Bank, 26 B. T. A. 421, followed. 2. In 1945 petitioner made recoveries of portions of bad debts charged off and allowed as deductions in prior years.

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1. For the taxable years 1944 and 1945, petitioner paid premiums on life insurance policies held as security for certain debts previously charged off to profit and loss in prior years. Held, deductible as ordinary and necessary business expenses. Dominion National Bank, 26 B. T. A. 421, followed. 2. In 1945 petitioner made recoveries of portions of bad debts charged off and allowed as deductions in prior years. Held, for failure to establish that such prior deductions resulted in no tax benefit, the recoveries constitute taxable income. 3. In computing petitioner's excess profits net income…

1Opinion of the Court

The Charleston National Bank, Charleston, West Virginia, a National Banking Association, Petitioner, v. Commissioner of Internal Revenue, Respondent

Charleston Nat'l Bank v. Commissioner

Docket No. 33231

United States Tax Court

20 T.C. 253; 1953 U.S. Tax Ct. LEXIS 172;

April 30, 1953, Promulgated

Decision will be entered under Rule 50.

1. For the taxable years 1944 and 1945, petitioner paid premiums on life insurance policies held as security for certain debts previously charged off to profit and loss in prior years. Held, deductible as ordinary and necessary business expenses. Dominion National…

2Cases cited4 opinions

  1. Gus Blass Co. v. CommissionerUnited States Tax Court · 1947
  2. First Nat. Bank & Trust Co. of Tulsa v. JonesCourt of Appeals for the Tenth Circuit · 1944
  3. First Nat. Bank & Trust Co. v. JonesDistrict Court, W.D. Oklahoma · 1943
  4. Charleston Nat'l Bank v. CommissionerUnited States Tax Court · 1953

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