High Plains Agricultural Credit Corp. v. Commissioner
United States Tax Court
Petitioner transferred to a bank with recourse loans made to ranchers and farmers. Held, under sec. 166(g)(2), petitioner, an endorser and a guarantor within the language of that provision, is prohibited from deducting additions to a reserve for bad debts to reflect the loans transferred.
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Petitioner transferred to a bank with recourse loans made to ranchers and farmers. Held, under sec. 166(g)(2), petitioner, an endorser and a guarantor within the language of that provision, is prohibited from deducting additions to a reserve for bad debts to reflect the loans transferred. Held, further, the Commissioner did not abuse his discretion when he determined that, with regard to loans not transferred, no deduction for additions to a reserve was reasonable in the taxable years.
1Opinion of the Court
High Plains Agricultural Credit Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
High Plains Agricultural Credit Corp. v. Commissioner
Docket No. 9170-72
United States Tax Court
63 T.C. 118; 1974 U.S. Tax Ct. LEXIS 27;
November 12, 1974, Filed
Decision will be entered for the respondent.
Petitioner transferred to a bank with recourse loans made to ranchers and farmers. Held, under sec. 166(g)(2), petitioner, an endorser and a guarantor within the language of that provision, is prohibited from deducting additions to a reserve for bad debts to reflect the loans transferred.…
2Cases cited33 opinions
- Shapiro v. ThompsonSupreme Court of the United States · 1969
- Bolling v. SharpeSupreme Court of the United States · 1954
- Frontiero v. RichardsonSupreme Court of the United States · 1973
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Kahn v. ShevinSupreme Court of the United States · 1974
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