Legal Opinion

Colorado County Federal Sav. & Loan Asso. v. Commissioner

United States Tax Court

Decided September 29, 1961No. Docket No. 77536PublishedCited by 17 opinions

In the determination of the deficiences for 1954 and 1955 the Commissioner determined that petitioner realized taxable income, before deduction for bad debts, in the amounts of $ 9,763.04 and $ 10,062.97, respectively. He also determined that no portion of these amounts was credited to a reserve for bad debts account or any other account established for the sole purpose of absorbing losses as is required by section 593, I.R.C. 1954, and regulations thereunder.

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In the determination of the deficiences for 1954 and 1955 the Commissioner determined that petitioner realized taxable income, before deduction for bad debts, in the amounts of $ 9,763.04 and $ 10,062.97, respectively. He also determined that no portion of these amounts was credited to a reserve for bad debts account or any other account established for the sole purpose of absorbing losses as is required by section 593, I.R.C. 1954, and regulations thereunder. He then determined that no deductions for bad debts are allowable to petitioner for the years 1954 and 1955 in the respective amounts…

1Opinion of the Court

OPINION.

Black, Judge:

The Commissioner has determined deficiencies in petitioner’s income tax for the years 1954 and 1955 in the amounts of $2,783.18 and $2,942.32, respectively. The deficiencies for 1954 and 1955 are due to one adjustment made by the Commissioner which is explained in the deficiency notice as follows:(a) For the years 1954 and 1955 you realized taxable income, before deduction, for bad debts in the amounts of $9,763.04 and $10,06'2.97, respectively. Since no portion of these amounts was credited to a reserve for bad debts account, or any other account, established for the…

2Cases cited2 opinions

  1. Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
  2. Arcadia Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1960

3Cited by17 opinions

  1. Commercial Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1969
  2. Leesburg Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1970
  3. Newport Federal Savings & Loan Ass'n v. United StatesDistrict Court, E.D. Arkansas · 1966
  4. Centralia Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1976
  5. Ohio Pike Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1970

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