Mercantile Nat'l Bank v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Banks -- Recoveries of Bad Debts. -- Section 433 (a) (1) (L) of the Internal Revenue Code of 1939, as added by the Excess Profits Tax Act of 1950, provides that for the purpose of computing excess profits net income, banks using the reserve method of accounting for bad debts shall deduct debts which became worthless within the taxable year in lieu of the amount allowable under the reserve method.
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1. Excess Profits Tax -- Banks -- Recoveries of Bad Debts. -- Section 433 (a) (1) (L) of the Internal Revenue Code of 1939, as added by the Excess Profits Tax Act of 1950, provides that for the purpose of computing excess profits net income, banks using the reserve method of accounting for bad debts shall deduct debts which became worthless within the taxable year in lieu of the amount allowable under the reserve method. Held, that neither subparagraph (L) nor any other provision of section 433 (a) requires that there shall be included in excess profits net income of such a bank any income…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income and excess profits taxes for the calendar years, and in the amounts as follows:
1951_Income tax_ $8,282. 98
1952_Income and excess profits tax_ 61, 777. 97
1953_Income and excess profits tax_ 24,459.69
The major portion of the excess profits tax deficiencies arises out of the respondent’s action in increasing excess profits net income by the amounts recovered in the taxable years on account of debts which had either been charged off as bad debts or had been charged to the reserve for bad debts in prior excess profits tax years. The…
2Cases cited13 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
- Gus Blass Co. v. CommissionerUnited States Tax Court · 1947
8 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Iowa-Des Moines Nat'l Bank v. CommissionerUnited States Tax Court · 1977
- Schultz v. CommissionerUnited States Tax Court · 1968
- Ruoff v. CommissionerUnited States Tax Court · 1958
- Heigerick v. CommissionerUnited States Tax Court · 1966
- Commissioner of Internal Revenue v. Mercantile National Bank at DallasCourt of Appeals for the Fifth Circuit · 1960
21 more not listed; retrieve them via the Exa API.