Home Sav. & Loan Asso. v. Commissioner
United States Tax Court
Petitioner, a savings and loan association, used the reserve method of accounting for bad debts in 1975 and, under the reserve method, used the experience method of computing its bad debt deduction for 1975. Petitioner maintained as a permanent part of its books and records (1) certain tax reserve accounts which are required for the use of the reserve method, (2) a reconciliation of these tax reserve accounts with its other reserve accounts, and (3) its Federal income tax…
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Petitioner, a savings and loan association, used the reserve method of accounting for bad debts in 1975 and, under the reserve method, used the experience method of computing its bad debt deduction for 1975. Petitioner maintained as a permanent part of its books and records (1) certain tax reserve accounts which are required for the use of the reserve method, (2) a reconciliation of these tax reserve accounts with its other reserve accounts, and (3) its Federal income tax return for 1975 which explained the entries made to the tax reserve accounts. Held, petitioner complied with the…
1Opinion of the Court
Goffe, Judge-.
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable years and in the amounts as follows:
Year Deficiency Year Deficiency
1969 . $263.15 1973 . $316,649.09
1970 . 398.24 1974 . 155,511.66
1971 . 996.19 1975 . 423,503.48
1972 . 271,034.31 1976 . 8,941.68
After concessions by the parties, the issues for decision are: (1) Whether the petitioner complied with the requirements of section 593, I.R.C. 1954, as amended, with respect to the reserve method of accounting for bad debts so as to be entitled to a bad debt deduction in the amount of $1,961,508…
2Cases cited14 opinions
- Graff v. CommissionerUnited States Tax Court · 1980
- Alvin v. Graff v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1982
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
- Sam E. Wyly v. United StatesCourt of Appeals for the Fifth Circuit · 1981
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Home Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1983