Central Pa. Sav. Ass'n v. Commissioner
United States Tax Court
During the taxable years at issue, P deducted additions to its bad debt reserve utilizing the percentage of taxable income method set forth in sec. 593(b)(2)(A), I.R.C.
Read the full summary
During the taxable years at issue, P deducted additions to its bad debt reserve utilizing the percentage of taxable income method set forth in sec. 593(b)(2)(A), I.R.C. In its calculations of taxable income for this purpose, P did not take into account net operating losses (NOL's) as provided in sec. 1.593-6A(b)(5)(vi) and (vii), Income Tax Regs.Held: Upon reconsideration, we no longer adhere to our prior holdings that such regulation is invalid; P must take NOL's into account in computing its taxable income under sec. 593(b)(2)(A), I.R.C., as required by such regulation. Georgia Federal Bank…
1Opinion of the Court
Central Pennsylvania Savings Association and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Central Pa. Sav. Ass'n v. Commissioner
Docket No. 19498-89
United States Tax Court
104 T.C. 384; 1995 U.S. Tax Ct. LEXIS 18; 104 T.C. No. 19;
March 30, 1995, Filed
An appropriate order will be issued and decision will be entered under Rule 155.
During the taxable years at issue, P deducted additions to its bad debt reserve utilizing the percentage of taxable income method set forth in sec. 593(b)(2)(A), I.R.C. In its calculations of taxable income for this purpose, P did not take…
Also in this document: Concurrence; Dissent.
2Cases cited49 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
- Securities & Exchange Commission v. Chenery Corp.Supreme Court of the United States · 1943
- Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
44 more not listed; retrieve them via the Exa API.