The First National Bank of La Feria v. Commissioner of Internal Revenue

PER CURIAM,

This petition attacks as erroneous the finding and decision of the Tax Court 1 sustaining the commissioner’s disallowance of a part of the amounts claimed by petitioner, under Mimeograph No. 6209, issued Dec. 8, 1947, as deductions, for the years 1947 and 1948, under Section 23 (k) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 23(k), for reasonable additions to its reserve for bad debts.

The claim made by petitioner below, and there disallowed, was that the commissioner acted arbitrarily, or unreasonably, or, at any rate, without authority of law in, first authorizing…