First Sav. & Loan Asso. v. Commissioner
United States Tax Court
1. Held, that the amount of accounts carried on the petitioner's books as "optional shares" did not constitute "deposits or withdrawable accounts of its depositors" for the purpose of the computation, under section 593 of the Internal Revenue Code of 1954, of the amount of the deduction to which the petitioner is entitled under section 166(c) of the Code as a reasonable addition to its reserve for bad debts. 2. Held, further, that amounts representing profit upon sales of…
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1. Held, that the amount of accounts carried on the petitioner's books as "optional shares" did not constitute "deposits or withdrawable accounts of its depositors" for the purpose of the computation, under section 593 of the Internal Revenue Code of 1954, of the amount of the deduction to which the petitioner is entitled under section 166(c) of the Code as a reasonable addition to its reserve for bad debts. 2. Held, further, that amounts representing profit upon sales of homes were properly included by the petitioner in its returns for each of the years in question.
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the taxable years 1956, 1957, and 1958 in the respective amounts of $6,054.45, $3,591.86, and $2,715.07. By amended answers respondent asserts a claim for increased deficiencies for 1957 and 1958 in the respective amounts of $7,628.41 and $13,211.32.
The issues for decision are (1) whether, in the years in question, certain “optional share” accounts should be treated as “deposits or withdrawable accounts” in computing deductible additions to petitioner’s reserve for bad debts under section 593 of .the Internal Revenue Code…
2Cases cited7 opinions
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