American Bank & Trust Co. v. Commissioner
United States Tax Court
Petitioner is a surviving bank by merger with another bank. In computing the limitation for its deductible addition to its reserve for bad debts under Rev. Rul. 64-334, for the taxable year 1964, petitioner must apply the combined bad debt ratios of both banks as of Dec. 31, 1963, even though the banks merged after that date because Rev. Rul. 64-334 must be construed in the light of Mim. 6209, Rev. Rul. 54-148, and Rev. Rul. 57-350.
1Opinion of the Court
OPINION
Gopue, Judge:
Respondent determined a deficiency in the Federal income tax of petitioner for the taxable year 1964 in the amount of $46,448. The sole issue for determination is whether petitioner, a national bank, properly computed an addition to its bad debt reserve for the taxable year 1964.
All of the facts have been stipulated. The stipulation of facts and exhibits' attached thereto are incorporated herein and adopted as our findings.
Petitioner (sometimes hereinafter referred to as American) is a corporation organized in 1932 under the laws of the Commonwealth of Pennsylvania. It is…
2Cases cited6 opinions
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Pullman Trust & Savings Bank v. United StatesDistrict Court, N.D. Illinois · 1963
- Pullman Trust & Savings Bank, an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1964
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1965
- The First National Bank in Olney v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- American Bank & Trust Co. v. CommissionerUnited States Tax Court · 1973