Legal Opinion
First Federal Savings & Loan Ass'n of Bristol v. United States
United States Court of Claims
Decided September 23, 1981No. 147-79TPublishedCited by 9 opinions
1Opinion of the CourtNichols, Judge
This is a suit by a savings and loan association described in Section 593 of the Internal Revenue Code of 1954, to recover overpayment of income taxes for 1975 and 1976, resulting from inclusion in income of rentals on foreclosed property, as required by defendant. The issue is the proper interpretation of §595 of the Code and the validity of a Treasury Regulation founded on § 595. There is no triable *570issue of fact. We hold for the plaintiff for reasons to be stated.
Plaintiff, First Federal Savings and Loan Association of Bristol (S&L) is in the business its name implies. It is limited by its…
2Cases cited2 opinions
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Estate of Lovett v. United StatesUnited States Court of Claims · 1980
3Cited by9 opinions
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Major Carl J. Sammt, R.A., Appellant/cross-Appellee v. The United States, Appellee/cross-AppellantCourt of Appeals for the Federal Circuit · 1985
- Gibraltar Financial Corporation of California, Etc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Gibraltar Financial Corp. v. United StatesUnited States Court of Claims · 1986
- Sammt v. United StatesUnited States Court of Claims · 1985
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