Legal Opinion
Gibraltar Financial Corp. v. United States
United States Court of Claims
Decided May 9, 1986No. Nos. 21-82T, 22-82TPublishedCited by 3 opinions
1Opinion of the Court
OPINION
MAYER, Judge.
Plaintiff Gibraltar Financial Corporation (GFC), seeks a tax refund because the In*32ternal Revenue Service (Service) improperly included amounts attributed to uncollected delinquent interest on defaulted real property loans in its gross income for 1972 and 1973. In plaintiffs view, these amounts, realized from the resale of properties securing defaulted loans, should be credited to its bad debt reserve account under section 595 of the Internal Revenue Code of 1954, 26 U.S.C. § 595. The case is here on cross-motions for summary judgment. The material facts are stipulated and…
2Cases cited15 opinions
- Mourning v. Family Publications Service, Inc.Supreme Court of the United States · 1973
- United States v. GilmoreSupreme Court of the United States · 1963
- Koshland v. HelveringSupreme Court of the United States · 1936
- Helvering v. Midland Mutual Life InsuranceSupreme Court of the United States · 1937
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
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3Cited by3 opinions
- Gibraltar Financial Corporation of California, Etc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Security Bank S.S.B. v. CommissionerUnited States Tax Court · 1995
- Security Bank S.S.B. v. CommissionerUnited States Tax Court · 1995