Idaho First Nat'l Bank v. Commissioner
United States Tax Court
Petitioner M acquired an insolvent bank through FDIC bidding processes and thereafter disposed of assets of the acquired bank and deducted losses realized in such sales on a consolidated return. Held, the losses incurred by M were incurred in rehabilitating the acquired bank and are not "built-in deductions" within the meaning of sec. 1.1502-15(a)(2), Income Tax Regs.
1Opinion of the Court
COHEN, Judge:
In these consolidated cases, respondent determined deficiencies in and additions to tax as follows:
Addition to tax
Case Year Deficiency Sec. 6661
1980 $976,837 Idaho First National
Docket No. 27381-88
Moore Financial Group 1981 181,469
Docket No. 27382-88 1983 22,105 $5,526
1984 2,528,808 632,202
1985 907.991 226.998
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue.
After concessions, the primary remaining issue, which is discussed and decided in this opinion, is whether certain losses incurred in disposing…
2Cases cited3 opinions
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