Leesburg Federal Sav. & Loan Asso. v. Commissioner
United States Tax Court
T, a domestic building and loan association, claimed deductions on its Federal income tax returns for additions made to a bad debt reserve account for qualifying real property loans. Except for information contained in its tax returns, T did not maintain any ledgers or accounts relating to bad debt reserves.
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T, a domestic building and loan association, claimed deductions on its Federal income tax returns for additions made to a bad debt reserve account for qualifying real property loans. Except for information contained in its tax returns, T did not maintain any ledgers or accounts relating to bad debt reserves. Held, assuming that copies of the income tax returns could otherwise qualify as part of petitioner's books of account, petitioner has failed to establish that any such copies were in fact maintained as a permanent part of its regular books of account as required by sec. 1.593-7(a), Income…
1Opinion of the Court
The Commissioner determined the following deficiencies in petitioner’s income tax:
Addition to taxi sec. 6651(a), Year Deficiency I.R.C. 1954
1965_ $22,885 $1, 145
1966___ 20, 640 _
The only question remaining for decision -is whether, in each of the years in issue, petitioner has satisfied the accounting requirements of section 598,1.R..C. 1954, and the regulations promulgated thereunder, and is therefore entitled to deductions for additions made to its accounts for bad debt reserves.
FINDINGS OF FACT
The parties have filed a stipulation of facts which, together with accompanying exhibits, is…
2Cases cited8 opinions
- Citizens Federal Savings and Loan Association of Cleveland v. United StatesCourt of Appeals for the Federal Circuit · 1961
- Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
- Arcadia Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1960
- Colorado County Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1961
- Commercial Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1969
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3Cited by11 opinions
- Allstate Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1977
- Centralia Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1976
- Ohio Pike Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1970
- Permanent Savings & Loan Ass'n v. United StatesDistrict Court, S.D. Ohio · 1977
- Home Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1983
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