American Bank & Trust Co. v. Commissioner
United States Tax Court
Petitioner is a surviving bank by merger with another bank. In computing the limitation for its deductible addition to its reserve for bad debts under Rev. Rul. 64-334, for the taxable year 1964, petitioner must apply the combined bad debt ratios of both banks as of Dec. 31, 1963, even though the banks merged after that date because Rev. Rul. 64-334 must be construed in the light of Mim. 6209, Rev. Rul. 54-148, and Rev. Rul. 57-350.
1Opinion of the Court
American Bank & Trust Company of Pa., Petitioner v. Commissioner of Internal Revenue, Respondent
American Bank & Trust Co. v. Commissioner
Docket No. 997-70
United States Tax Court
60 T.C. 807; 1973 U.S. Tax Ct. LEXIS 70; 60 T.C. No. 84;
August 29, 1973, Filed
Decision will be entered for the respondent.
Petitioner is a surviving bank by merger with another bank. In computing the limitation for its deductible addition to its reserve for bad debts under Rev. Rul. 64-334, for the taxable year 1964, petitioner must apply the combined bad debt ratios of both banks as of Dec. 31, 1963, even though the…
2Cases cited7 opinions
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Pullman Trust & Savings Bank v. United StatesDistrict Court, N.D. Illinois · 1963
- Pullman Trust & Savings Bank, an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1964
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1965
- The First National Bank in Olney v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966
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