Pacific First Fed. Sav. Bank v. Commissioner
United States Tax Court
R issued regulations changing the manner in which mutual savings banks calculated the allowable deduction for addition to bad debt reserves. Sec. 1.593-6A(b)(5), Income Tax Regs. As originally issued, the regulations were to operate prospectively only.
Read the full summary
R issued regulations changing the manner in which mutual savings banks calculated the allowable deduction for addition to bad debt reserves. Sec. 1.593-6A(b)(5), Income Tax Regs. As originally issued, the regulations were to operate prospectively only. R, however, subsequently amended the regulation to provide that, where net operating losses arising in years after the effective date were carried back to years before such date, the deduction for addition to bad debt reserve for such years was to be recalculated in the manner provided in the revised regulations. Held, retroactive application…
1Opinion of the Court
Pacific First Federal Savings Bank, Petitioner v. Commissioner of Internal Revenue, Respondent *
Pacific First Fed. Sav. Bank v. Commissioner
Docket No. 27606-87
United States Tax Court
101 T.C. 117; 1993 U.S. Tax Ct. LEXIS 49; 101 T.C. No. 7;
July 28, 1993, Filed
Decision will be entered under Rule 155.
R issued regulations changing the manner in which mutual savings banks calculated the allowable deduction for addition to bad debt reserves. Sec. 1.593-6A(b)(5), Income Tax Regs. As originally issued, the regulations were to operate prospectively only. R, however, subsequently amended the regulation…
2Cases cited34 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- United States v. CorrellSupreme Court of the United States · 1967
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
29 more not listed; retrieve them via the Exa API.