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
FisiieR, Judge:
This case involves deficiencies determined by respondent in the following amounts:
1954 _$49,986.66
1955 _ 84,689.54
The parties agree that petitioner was entitled to a deduction of $596.88 for amortization and depreciation in each of the j'ears 1954 and 1955 which had not been claimed on petitioner’s returns. The sole issue before us is whether petitioner in computing its bad debt deductions for the years in question was entitled to base its computations on the average of the annual percentages for each of 20 specified years. (Method 2.)
PINDINUS OP PACT.
The stipulated facts are…
2Cases cited8 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
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Pullman Trust & Savings Bank v. United StatesDistrict Court, N.D. Illinois · 1963
- North Carolina National Bank v. The United StatesUnited States Court of Claims · 1965
- Central Bank Co. v. CommissionerUnited States Tax Court · 1963
- Union National Bank of Youngstown v. United StatesDistrict Court, N.D. Ohio · 1965
- Boardwalk Nat'l Bank v. CommissionerUnited States Tax Court · 1960
4 more not listed; retrieve them via the Exa API.