Legal Opinion

First Nat'l Bank v. Commissioner

United States Tax Court

Decided April 30, 1954No. Docket No. 44642Published

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

  1. Stockly v. CommissionerUnited States Tax Court · 1954
  2. Corporation of America v. CommissionerUnited States Tax Court · 1945
  3. First Nat'l Bank v. CommissionerUnited States Tax Court · 1954

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