Burbank Liquidating Corp. v. Commissioner
United States Tax Court
1. Held, petitioners, who sold savings and loan businesses with agreement to repurchase any mortgage notes defaulted within 18 months after the sale, are required to include in income for the year of sale the balance of the reserves for bad debts established in connection with the notes transferred and deducted from taxable income. 2. Held, further, the petitioner United failed to establish that the balance of its reserve for bad debts was less than the amount stated in the…
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1. Held, petitioners, who sold savings and loan businesses with agreement to repurchase any mortgage notes defaulted within 18 months after the sale, are required to include in income for the year of sale the balance of the reserves for bad debts established in connection with the notes transferred and deducted from taxable income. 2. Held, further, the petitioner United failed to establish that the balance of its reserve for bad debts was less than the amount stated in the deficiency notice. 3. Held, further, the petitioner United is entitled to an ordinary loss deduction for a $ 250,000…
1Opinion of the Court
OPINION.
Fax, Judge:
The respondent contends that the petitioners were required to include the balance of their reserve for bad debt accounts, insofar as they represent amounts deducted after December 31, 1951, in income for the year in which they transferred the debts to which the reserves were applicable. The petitioners, however, contend that they were entitled to maintain these reserve accounts throughout the year in issue.
In Arcadia Savings & Loan Association, 34 T.C. 679 (1960), affd. 300 F. 2d 247 (C.A. 9, 1962), this Court held that a savings and loan association was required to include…
2Cases cited9 opinions
- Alice E. Cohn, Marion A. Cohn, Daniel E. Cohn, and Edgar M. Cohn v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Arcadia Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1960
- Wilkins Pontiac v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Wilkins PontiacCourt of Appeals for the Ninth Circuit · 1961
- Wilkins Pontiac v. CommissionerUnited States Tax Court · 1960
- Investors Diversified Services, Inc. v. CommissionerUnited States Tax Court · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- American Express Company and Affiliated Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2001
- Investers Diversified Services, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Redwood Empire Savings & Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Cramer v. CommissionerUnited States Tax Court · 1993
13 more not listed; retrieve them via the Exa API.