Centralia Federal Sav. & Loan Asso. v. Commissioner
United States Tax Court
Petitioners, domestic building and loan associations, elected the reserve method for bad debts, and computed their annual additions to reserves under the "percentage of taxable income method." However, instead of crediting such additions to their "reserve for losses on qualifying real property loans," petitioners, during the years in issue, credited such additions to different reserve accounts denominated "Federal Insurance Reserve" and "Reserve for Contingencies."
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Petitioners, domestic building and loan associations, elected the reserve method for bad debts, and computed their annual additions to reserves under the "percentage of taxable income method." However, instead of crediting such additions to their "reserve for losses on qualifying real property loans," petitioners, during the years in issue, credited such additions to different reserve accounts denominated "Federal Insurance Reserve" and "Reserve for Contingencies." These two accounts were considered as constituting together a single reserve account -- the federal insurance reserve -- and were…
1Opinion of the Court
Centralia Federal Savings and Loan Association, Petitioner v. Commissioner of Internal Revenue, Respondent; Evergreen First Federal Savings and Loan Association, Petitioner v. Commissioner of Internal Revenue, Respondent
Centralia Federal Sav. & Loan Asso. v. Commissioner
Docket Nos. 1685-74, 1686-74
United States Tax Court
66 T.C. 599; 1976 U.S. Tax Ct. LEXIS 81;
June 28, 1976, Filed
Decisions will be entered under Rule 155.
Petitioners, domestic building and loan associations, elected the reserve method for bad debts, and computed their annual additions to reserves under the "percentage of taxable…
2Cases cited16 opinions
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- Nash v. United StatesSupreme Court of the United States · 1970
- West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
- Citizens Federal Savings and Loan Association of Cleveland v. United StatesCourt of Appeals for the Federal Circuit · 1961
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