Legal Opinion
Atlantic Discount Company, Inc., Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-Cross
Court of Appeals for the Fifth Circuit
Decided January 30, 1973No. 72-2289PublishedCited by 10 opinions
1Opinion of the Court
AINSWORTH, Circuit Judge:
Atlantic Discount, Inc. is ehgaged in the business of financing both retail and wholesale purchasers of automobiles and other consumer goods. In anticipation of a certain percentage of loans being uncollectible, Atlantic established a reserve for bad debts. At issue in this case is the reasonableness of Atlantic’s additions to the reserve for the years 1963 and 1964, which were deducted for tax purposes under section 166(c) of the Internal Revenue Code of 1954, 26 U.S.C. § 166(c) (1971).
Taxpayer justified the additions by resorting inter alia to general industry and…
2Cases cited12 opinions
- Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Black Motor Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
- S. W. Coe & Co. v. V. Y. Dallman, Collector of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954
- Maverick-Clarke Litho Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
7 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Valmont Industries, Inc. v. CommissionerUnited States Tax Court · 1980
- Beneficial Corporation and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Houston Agricultural Credit Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- Time Acceptance, Inc. v. CommissionerUnited States Tax Court · 1985
5 more not listed; retrieve them via the Exa API.