First Nat'l Bank v. Commissioner
United States Tax Court
Petitioner, a national banking corporation in existence for a period of more than 20 years, used the loss ratio experience of another bank in the locality in computing its reserve for bad debts in the taxable years 1947 and 1948. Petitioner challenges as arbitrary and unreasonable the respondent's use of its own experience in determining the deficiencies in question.
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Petitioner, a national banking corporation in existence for a period of more than 20 years, used the loss ratio experience of another bank in the locality in computing its reserve for bad debts in the taxable years 1947 and 1948. Petitioner challenges as arbitrary and unreasonable the respondent's use of its own experience in determining the deficiencies in question. On the facts, held, petitioner has failed to show that the respondent's determination was either an arbitrary or an unreasonable exercise of his discretion.
1Opinion of the Court
OPINION.
LeMiRE, Judge:
The question presented is whether petitioner, a national banking corporation, must use its own experience in determining additions to its reserve for bad debts for 1947 and 1948, or whether it is entitled to use the experience of other banks in the locality having loans comparable in their nature and risk involved to those outstanding on petitioner’s books at the close of each of the taxable years involved.
Petitioner contends that it is entitled to use the bad debt experience of another bank, the First National Bank of Mercedes, instead of its own experience in…
2Cases cited2 opinions
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
3Cited by16 opinions
- American State Bank, a Wisconsin Banking Corporation v. United States of America, (Two Cases)Court of Appeals for the Seventh Circuit · 1960
- Union National Bank & Trust Co. of Elgin v. CommissionerUnited States Tax Court · 1956
- The First National Bank of La Feria v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1965
- American State Bank v. United StatesDistrict Court, E.D. Wisconsin · 1959
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