Legal Opinion

Allstate Sav. & Loan Asso. v. Commissioner

United States Tax Court

Decided June 7, 1977No. Docket No. 1674-74Published

Held, the expenses incurred by a building and loan association in selling foreclosed property in 1968 and 1969 are not deductible under sec. 162(a), I.R.C. 1954, but must be taken into account in making charges and credits to the association's reserve for losses from qualifying real property loans pursuant to sec. 595, I.R.C. 1954.

1Opinion of the Court

Allstate Savings & Loan Association, Successor in Interest to Metropolitan Savings & Loan Association of Los Angeles, Petitioner v. Commissioner of Internal Revenue, Respondent

Allstate Sav. & Loan Asso. v. Commissioner

Docket No. 1674-74

United States Tax Court

68 T.C. 310; 1977 U.S. Tax Ct. LEXIS 98;

June 7, 1977, Filed

Decision will be entered under Rule 155.

Held, the expenses incurred by a building and loan association in selling foreclosed property in 1968 and 1969 are not deductible under sec. 162(a), I.R.C. 1954, but must be taken into account in making charges and credits to the…

2Cases cited17 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Dixon v. United StatesSupreme Court of the United States · 1965
  4. Woodward v. CommissionerSupreme Court of the United States · 1970
  5. United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970

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