Commercial Sav. & Loan Asso. v. Commissioner
United States Tax Court
Held, the failure of Allied Building & Loan Association to establish the reserves required by sec. 593, I.R.C. 1954, as amended by the Revenue Act of 1962, until 23 months and 11 months, respectively, after the close of its taxable years, precludes the allowance of any deductions for 1963 and 1964 for additions to its bad debt reserves.
1Opinion of the Court
OPINION
Beuce, Judge:
Respondent determined deficiencies in income taxes of Allied Building & Loan Association for the calendar years 1963 and 1964 in the amounts of $8,536.26 and $9,538.12, respectively. The petitioner is successor of Allied Building & Loan Association by merger. The sole issue remaining for decision is whether Allied is entitled to claimed deductions for additions to its reserves for bad debts for the taxable years.
All the facts are stipulated. The stipulation and the exhibits attached thereto are incorporated by this reference.
The petitioner, Commercial Savings & Loan…
2Cases cited9 opinions
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Frentz v. CommissionerUnited States Tax Court · 1965
- J. William Frentz v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
- Pestcoe v. CommissionerUnited States Tax Court · 1963
- Scaife Co. v. CommissionerSupreme Court of the United States · 1941
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Leesburg Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1970
- Centralia Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1976
- Ohio Pike Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1970
- Home Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1983
- Peoples Federal Savings & Loan Ass'n v. United StatesDistrict Court, D. South Carolina · 1970
8 more not listed; retrieve them via the Exa API.