Legal Opinion
The First National Bank of Chicago v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided January 31, 1977No. 76-1284PublishedCited by 3 opinions
1Per curiam
In the taxable year 1968, taxpayer First National Bank of Chicago included $19,136,-794.50 of advances to its Trust Department in its loan base for computing its bad debt deduction. Judge Fay of the Tax Court upheld this method and therefore decided that taxpayer had overpaid its income tax by $85,622.12. The Commissioner appealed. We reverse.
As part of its operation, taxpayer maintains a Trust Department and keeps a separate set of books for that department. The Trust Department maintains an income account, a principal account and a securities account for each trust it administers. In making…
2Cases cited12 opinions
- Indus. Valley Bank & Trust Co. v. Comm'rUnited States Tax Court · 1976
- The Paramount Finance Company v. The United States. Edward T. Kirtz and Rosalyn S. Kirtz v. The United StatesUnited States Court of Claims · 1962
- American State Bank, a Wisconsin Banking Corporation v. United States of America, (Two Cases)Court of Appeals for the Seventh Circuit · 1960
- Merchants Industrial Bank, a Corporation Organized and Existing Under the Laws of the State of Colorado v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Pullman Trust & Savings Bank v. United StatesDistrict Court, N.D. Illinois · 1963
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3Cited by3 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Thor Power Tool Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1977
- Willard v. CommissionerUnited States Tax Court · 1983