First Commercial Bank v. Commissioner
United States Tax Court
Held, petitioner failed to show compliance with Mimeograph 6209, 1947-2 C.B. 26, and Rev. Rul. 54-148, 1954-1 C.B. 60, in computing a reasonable addition to a reserve for bad debts in the following respects: (a) A failure to eliminate the insured portion of Government-insured loans from the loans outstanding at the end of the year before applying the bad debt factor, and (b) a failure to use petitioner's own bad debt experience for the entire time it was in existence.
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Held, petitioner failed to show compliance with Mimeograph 6209, 1947-2 C.B. 26, and Rev. Rul. 54-148, 1954-1 C.B. 60, in computing a reasonable addition to a reserve for bad debts in the following respects: (a) A failure to eliminate the insured portion of Government-insured loans from the loans outstanding at the end of the year before applying the bad debt factor, and (b) a failure to use petitioner's own bad debt experience for the entire time it was in existence. Held, further, that petitioner has not shown that its reserve for bad debts on July 1, 1959, was inadequate and unreasonable…
1Opinion of the Court
The First Commercial Bank, Petitioner, v. Commissioner of Internal Revenue, Respondent
First Commercial Bank v. Commissioner
Docket No. 4322-62
United States Tax Court
45 T.C. 175; 1965 U.S. Tax Ct. LEXIS 15;
November 26, 1965, Filed
Decision will be entered under Rule 50.
Held, petitioner failed to show compliance with Mimeograph 6209, 1947-2 C.B. 26, and Rev. Rul. 54-148, 1954-1 C.B. 60, in computing a reasonable addition to a reserve for bad debts in the following respects: (a) A failure to eliminate the insured portion of Government-insured loans from the loans outstanding at the end of the year…
2Cases cited18 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- C. P. Ford & Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- American State Bank, a Wisconsin Banking Corporation v. United States of America, (Two Cases)Court of Appeals for the Seventh Circuit · 1960
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