First Nat'l Bank v. Commissioner
United States Tax Court
Recovery Exclusion -- Bad Debt -- Amount Which "Did Not" Reduce Tax -- Loss Shown on Return Controls -- Sec. 22 (b) (12) (D), I. R. C. -- The amount of the bad debt charge-offs which did not reduce the tax for the year of the charge-off is determined from the return filed by the taxpayer for the year and tacitly approved by the Commissioner and cannot be increased by considering additional deductions and exclusions which could have been but were not shown on the return.
1Opinion of the Court
First National Bank, Petitioner, v. Commissioner of Internal Revenue, Respondent
First Nat'l Bank v. Commissioner
Docket No. 44642
United States Tax Court
22 T.C. 209; 1954 U.S. Tax Ct. LEXIS 220;
April 30, 1954, Filed. April 30, 1954, Filed
Decision will be entered for the respondent.
Recovery Exclusion -- Bad Debt -- Amount Which "Did Not" Reduce Tax -- Loss Shown on Return Controls -- Sec. 22 (b) (12) (D), I. R. C. -- The amount of the bad debt charge-offs which did not reduce the tax for the year of the charge-off is determined from the return filed by the taxpayer for the year and tacitly…
2Cases cited3 opinions
- Stockly v. CommissionerUnited States Tax Court · 1954
- Corporation of America v. CommissionerUnited States Tax Court · 1945
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1954