Home Group v. Commissioner
United States Tax Court
S, a consolidated subsidiary of P, was a qualified organization entitled to claim a bad debt reserve addition under the provisions of sec. 593, I.R.C. 1954. Sec. 593, I.R.C. 1954, affords qualified taxpayers broad discretion to determine the amount of the reserve addition, up to the maximum limit set out in three statutory formulae.
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S, a consolidated subsidiary of P, was a qualified organization entitled to claim a bad debt reserve addition under the provisions of sec. 593, I.R.C. 1954. Sec. 593, I.R.C. 1954, affords qualified taxpayers broad discretion to determine the amount of the reserve addition, up to the maximum limit set out in three statutory formulae. Sec. 1.593-6(a)(3), Income Tax Regs., would prohibit qualified taxpayers from subsequently (after return filed) going back and reducing the reserve "for purposes of obtaining a larger deduction in a later year." During 1978, sec. 1.593-6A, Income Tax Regs., was…
1Opinion of the Court
OPINION
GERBER, Judge:
This controversy was generated by the parties’ differing computations under Rule 155,1 pursuant to our opinion rendered in this case.2 The Rule 155 controversy centered about section 593, which places limits upon the addition to the reserve for bad debts of certain savings banks. See sec. 593(b)(1). During the taxable year in question, petitioner’s consolidated subsidiary was a savings bank subject to section 593. This section also permits a taxpayer broad discretion to determine the amount of the addition to the reserve, not to exceed the limits set forth in section…
2Cases cited13 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
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3Cited by31 opinions
- Harris v. CommissionerUnited States Tax Court · 1992
- Chimblo v. CommissionerCourt of Appeals for the Second Circuit · 1999
- AmBase Corp. v. United StatesCourt of Appeals for the Second Circuit · 2013
- Chimblo v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1999
- David B. Greenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2021
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