Legal Opinion

Rio Grande Bldg. & Loan Ass'n v. Commissioner

United States Tax Court

Decided July 12, 1961No. Docket No. 72236Published

1. Petitioner, a savings and loan association, elected to claim its bad debt deductions under the reserve method for the years 1953 through 1955. For each of these years, petitioner deducted the full amount of its net income as a bad debt deduction. It bases its claim for such deductions on the ground that the amounts deducted were, by implication, determined to be reasonable reserve additions under the provisions of the applicable Internal Revenue Code.

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1. Petitioner, a savings and loan association, elected to claim its bad debt deductions under the reserve method for the years 1953 through 1955. For each of these years, petitioner deducted the full amount of its net income as a bad debt deduction. It bases its claim for such deductions on the ground that the amounts deducted were, by implication, determined to be reasonable reserve additions under the provisions of the applicable Internal Revenue Code. Only part of the amounts was credited to any reserve account. Held, that for each of the years in issue, petitioner's allowable bad debt…

1Opinion of the Court

Rio Grande Building & Loan Association, Petitioner, v. Commissioner of Internal Revenue, Respondent

Rio Grande Bldg. & Loan Ass'n v. Commissioner

Docket No. 72236

United States Tax Court

36 T.C. 657; 1961 U.S. Tax Ct. LEXIS 112;

July 12, 1961, Filed

Decision will be entered under Rule 50.

1. Petitioner, a savings and loan association, elected to claim its bad debt deductions under the reserve method for the years 1953 through 1955. For each of these years, petitioner deducted the full amount of its net income as a bad debt deduction. It bases its claim for such deductions on the ground that the…

2Cases cited10 opinions

  1. West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
  2. West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
  3. Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
  4. Arcadia Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1960
  5. Farmville Oil & Fertilizer Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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