Rio Grande Bldg. & Loan Ass'n v. Commissioner
United States Tax Court
1. Petitioner, a savings and loan association, elected to claim its bad debt deductions under the reserve method for the years 1953 through 1955. For each of these years, petitioner deducted the full amount of its net income as a bad debt deduction. It bases its claim for such deductions on the ground that the amounts deducted were, by implication, determined to be reasonable reserve additions under the provisions of the applicable Internal Revenue Code.
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1. Petitioner, a savings and loan association, elected to claim its bad debt deductions under the reserve method for the years 1953 through 1955. For each of these years, petitioner deducted the full amount of its net income as a bad debt deduction. It bases its claim for such deductions on the ground that the amounts deducted were, by implication, determined to be reasonable reserve additions under the provisions of the applicable Internal Revenue Code. Only part of the amounts was credited to any reserve account. Held, that for each of the years in issue, petitioner's allowable bad debt…
1Opinion of the Court
Fisher, Judge:
The Commissioner determined deficiencies in income tax of Bio Grande Building & Loan Association (hereinafter sometimes called the association) as follows:
1953-$14, 520. 00
1954- 17, 234.21
1955- 22, 522.26
Total- 54,276.47
The issue for our determination is whether petitioner, during any or all of the years in issue, is to be allowed any deduction for bad debts under the reserve method, and, if so, in what amount under section 23 (k) (1) of the 1939 Code and section 593 of the 1954 Code.
FINDINGS OF FACT.
Some of the facts have been stipulated and are so found.
Petitioner is organized…
2Cases cited9 opinions
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- Farmville Oil & Fertilizer Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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