Allstate Sav. & Loan Asso. v. Commissioner
United States Tax Court
Held, the expenses incurred by a building and loan association in selling foreclosed property in 1968 and 1969 are not deductible under sec. 162(a), I.R.C. 1954, but must be taken into account in making charges and credits to the association's reserve for losses from qualifying real property loans pursuant to sec. 595, I.R.C. 1954.
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes as successor in interest to Metropolitan Savings & Loan Association of Los Angeles:
1968. $47,207
1969.. 7,975
Other issues having been settled by the parties, the only issue for decision is whether commissions and other selling expenses incurred by petitioner in disposing of foreclosed property are deductible under section 1621 or are chargeable to the reserve for losses from qualified loans pursuant to section 595.
All the facts are stipulated.
Metropolitan Savings & Loan Association…
2Cases cited16 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Crane v. CommissionerSupreme Court of the United States · 1947
- Dixon v. United StatesSupreme Court of the United States · 1965
- Woodward v. CommissionerSupreme Court of the United States · 1970
- United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
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3Cited by12 opinions
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
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- Paulsen v. CommissionerUnited States Tax Court · 1982
- Allstate Savings & Loan Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1979
- Allstate Savings & Loan Association v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
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