Boardwalk Nat'l Bank v. Commissioner
United States Tax Court
Petitioner, a national banking corporation, which had formerly used the specific chargeoff method of deducting bad debts, adopted the reserve method based on a 20-year moving average in 1947, pursuant to Mim. 6209 (1947-2 C.B. 26). In computing its moving average percentage of bad debt losses to outstanding loans, petitioner used the overall average loss for all 20 years.
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Petitioner, a national banking corporation, which had formerly used the specific chargeoff method of deducting bad debts, adopted the reserve method based on a 20-year moving average in 1947, pursuant to Mim. 6209 (1947-2 C.B. 26). In computing its moving average percentage of bad debt losses to outstanding loans, petitioner used the overall average loss for all 20 years. (Method 1.) Prior to the due date of its 1950 return, petitioner sought respondent's permission to change to a computation based on the average of the annual percentages for each of the 20 years. (Method 2.) Such permission…
1Opinion of the Court
The Boardwalk National Bank of Atlantic City, Petitioner, v. Commissioner of Internal Revenue, Respondent
Boardwalk Nat'l Bank v. Commissioner
Docket No. 70527
United States Tax Court
34 T.C. 937; 1960 U.S. Tax Ct. LEXIS 81;
September 14, 1960, Filed
Decision will be entered under Rule 50.
Petitioner, a national banking corporation, which had formerly used the specific chargeoff method of deducting bad debts, adopted the reserve method based on a 20-year moving average in 1947, pursuant to Mim. 6209 (1947-2 C.B. 26). In computing its moving average percentage of bad debt losses to outstanding loans,…
2Cases cited9 opinions
- Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
- Commissioner v. ConnellySupreme Court of the United States · 1949
- 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
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1955
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