Ohio Pike Sav. & Loan Co. v. Commissioner
United States Tax Court
The Commissioner disallowed several deductions -- including the deduction for additions made to a bad debt reserve for qualifying real property loans -- claimed for the taxable year by T, a domestic building and loan association. The deduction for additions to the bad debt reserve was disallowed because T did not fulfill the accounting requirements of sec. 593, I.R.C. 1954, and the regulations thereunder. T does not dispute the disallowance of these deductions.
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The Commissioner disallowed several deductions -- including the deduction for additions made to a bad debt reserve for qualifying real property loans -- claimed for the taxable year by T, a domestic building and loan association. The deduction for additions to the bad debt reserve was disallowed because T did not fulfill the accounting requirements of sec. 593, I.R.C. 1954, and the regulations thereunder. T does not dispute the disallowance of these deductions. The effect of these adjustments was to increase T's taxable income for the year in issue. The amount of taxable income is a factor to…
1Opinion of the Court
The Commissioner determined a deficiency of $241.95 in petitioner’s income tax for the calendar year 1964. He disallowed several deductions, including the deduction for additions to bad debt reserves, claimed by the petitioner for the taxable year in issue. These adjustments bad the effect of increasing petitioner’s taxable income for that year. The only question remaining for decision is 'whether section 1.593-5 (b) (2), Income Tax Regs., permits the petitioner to credit part of this increase in its taxable income to its bad debt reserves, and thereby claim a deduction under section…
2Cases cited4 opinions
- Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
- Colorado County Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1961
- Commercial Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1969
- Leesburg Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1970
3Cited by2 opinions
- Annapolis Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1972
- Ohio Pike Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1970