First Nat'l Bank v. Commissioner
United States Tax Court
For business reasons, petitioner created a wholly owned subsidiary mortgage company to which it loaned funds for use in making loans for home purchases and construction.
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For business reasons, petitioner created a wholly owned subsidiary mortgage company to which it loaned funds for use in making loans for home purchases and construction. Petitioner filed consolidated returns with the mortgage company for 1974 and 1975. In these returns, petitioner elected to take its bad debt deduction under the reserve method authorized by sec. 166(c), I.R.C. 1954, and to compute its additions to its bad debt reserve under the percentage method authorized by sec. 585(b)(2), I.R.C. 1954. Petitioner included its loans to the mortgage company in its base for computing its 1974…
1Opinion of the Court
First National Bank in Little Rock, Petitioner v. Commissioner of Internal Revenue, Respondent
First Nat'l Bank v. Commissioner
Docket No. 2694-80
United States Tax Court
83 T.C. 202; 1984 U.S. Tax Ct. LEXIS 41; 83 T.C. No. 13;
August 14, 1984. August 14, 1984, Filed
Decision will be entered under Rule 155.
For business reasons, petitioner created a wholly owned subsidiary mortgage company to which it loaned funds for use in making loans for home purchases and construction. Petitioner filed consolidated returns with the mortgage company for 1974 and 1975. In these returns, petitioner elected to take…
2Cases cited17 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Handy & Harman v. BurnetSupreme Court of the United States · 1931
- Graff v. CommissionerUnited States Tax Court · 1980
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