First Nat'l Bank v. Commissioner
United States Tax Court
The petitioner was organized on July 9, 1934, and for the years 1929 through 1933 used the loss ratio experience of a certain bank in the locality and an adapted loss ratio experience of that bank for 1934 in computing its reserve for bad debts in the taxable years 1957 through 1960. On the facts, held, that the balance of the petitioner's reserve for bad debts on January 1, 1957, was adequate and reasonable for the taxable years 1957 through 1960 without any additions…
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The petitioner was organized on July 9, 1934, and for the years 1929 through 1933 used the loss ratio experience of a certain bank in the locality and an adapted loss ratio experience of that bank for 1934 in computing its reserve for bad debts in the taxable years 1957 through 1960. On the facts, held, that the balance of the petitioner's reserve for bad debts on January 1, 1957, was adequate and reasonable for the taxable years 1957 through 1960 without any additions thereto for those years.
1Opinion of the Court
Withey, Judge:
The Commissioner has determined deficiencies in the income tax of the petitioner in the amounts of $3,975.99, $7,070.44, $5,330.43, and $7,543.15 for the years 1957, 1958, 1959, and 1960, respectively. The sole issue presented is the correctness of the Commissioner’s action in disallowing deductions of $7,646.14, $10,207.58, $10,267.69, and $14,856.87 taken by petitioner in its income tax returns for 1957,1958,1959, and 1960, respectively, as additions to its reserve for bad debts for the respective years.
FINDINGS OF FACT
Some of the facts have been stipulated and are found…
2Cases cited17 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- C. P. Ford & Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- American State Bank, a Wisconsin Banking Corporation v. United States of America, (Two Cases)Court of Appeals for the Seventh Circuit · 1960
12 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Massachusetts Business Development Corp. v. CommissionerUnited States Tax Court · 1969
- The First National Bank in Olney v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966
- First Commercial Bank v. CommissionerUnited States Tax Court · 1965
- American Bank & Trust Co. v. CommissionerUnited States Tax Court · 1973
- American Bank & Trust Co. v. CommissionerUnited States Tax Court · 1973
5 more not listed; retrieve them via the Exa API.