First Commercial Bank v. Commissioner
United States Tax Court
Held, petitioner failed to show compliance with Mimeograph 6209, 1947-2 C.B. 26, and Rev. Rul. 54-148, 1954-1 C.B. 60, in computing a reasonable addition to a reserve for bad debts in the following respects: (a) A failure to eliminate the insured portion of Government-insured loans from the loans outstanding at the end of the year before applying the bad debt factor, and (b) a failure to use petitioner's own bad debt experience for the entire time it was in existence.
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Held, petitioner failed to show compliance with Mimeograph 6209, 1947-2 C.B. 26, and Rev. Rul. 54-148, 1954-1 C.B. 60, in computing a reasonable addition to a reserve for bad debts in the following respects: (a) A failure to eliminate the insured portion of Government-insured loans from the loans outstanding at the end of the year before applying the bad debt factor, and (b) a failure to use petitioner's own bad debt experience for the entire time it was in existence. Held, further, that petitioner has not shown that its reserve for bad debts on July 1, 1959, was inadequate and unreasonable…
1Opinion of the Court
Soott, Judge:
Respondent determined deficiencies in petitioner’s income tax in the amounts of $46,114.69- for the taxable year ended June SO, 1960, and $10,370.84 for the short taxable year July 1, 1960, through December 31,1960.
The issue for decision is whether petitioner should be allowed deductions for additions to its reserve for bad debts in the respective amounts of $85,852.22 and $23,000 for its taxable year ended June 30, 1960, and its short taxable year July 1, 1960, through December 31, 1960.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioner,…
2Cases cited17 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- C. P. Ford & Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- American State Bank, a Wisconsin Banking Corporation v. United States of America, (Two Cases)Court of Appeals for the Seventh Circuit · 1960
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3Cited by4 opinions
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1984
- First Commercial Bank v. CommissionerUnited States Tax Court · 1965
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1984
- Zions First Nat'l Bank v. CommissionerUnited States Tax Court · 1974