Legal Opinion
Peoples Federal Savings and Loan Association of Sidney v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 9, 1992No. 90-1939PublishedCited by 48 opinions
1Opinion of the Court
MILBURN, Circuit Judge.
The Commissioner of Internal Revenue (“Commissioner”) appeals the decision of the United States Tax Court determining that the appellee, Peoples Federal Savings and Loan Association of Sidney, Ohio (“taxpayer”), owed a tax deficiency for 1978, but was entitled to refunds for 1979 and 1980.
From 1964 to 1978, the Commissioner had in force a regulation, 26 C.F.R. § 1.593-6(b)(2)(iv), which provided that, for purposes of the “percentage of taxable income” method of computing the deduction for additions to loan loss reserves under 26 U.S.C. § 593, a carryback year’s taxable…
2Cases cited13 opinions
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- Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
- Rust v. SullivanSupreme Court of the United States · 1991
- Morton v. RuizSupreme Court of the United States · 1974
- National Labor Relations Board v. Bell Aerospace Co.Supreme Court of the United States · 1974
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3Cited by48 opinions
- Bankers Life and Casualty Company v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Brown v. Rock Creek Mining Co.Court of Appeals for the Sixth Circuit · 1993
- Central Pa. Sav. Ass'n v. CommissionerUnited States Tax Court · 1995
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
- Hospital Corporation of America & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2004
43 more not listed; retrieve them via the Exa API.