Pacific First Fed. Sav. Bank v. Commissioner
United States Tax Court
R issued regulations changing the manner in which mutual savings banks calculated the allowable deduction for addition to bad debt reserves. Sec. 1.593-6A(b)(5), Income Tax Regs. As originally issued, the regulations were to operate prospectively only.
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R issued regulations changing the manner in which mutual savings banks calculated the allowable deduction for addition to bad debt reserves. Sec. 1.593-6A(b)(5), Income Tax Regs. As originally issued, the regulations were to operate prospectively only. R, however, subsequently amended the regulation to provide that, where net operating losses arising in years after the effective date were carried back to years before such date, the deduction for addition to bad debt reserve for such years was to be recalculated in the manner provided in the revised regulations. Held, retroactive application…
1Opinion of the Court
SUPPLEMENTAL OPINION
Wells, Judge:
The instant case is before us on remand from the Court of Appeals for the Ninth Circuit. In Pacific First Fed. Sav. Bank v. Commissioner, 961 F.2d 800 (9th Cir. 1992), revg. and remanding 94 T.C. 101 (1990), the Court of Appeals reversed our decision that section 1.593-6A(b)(5)(vi) and (vii), Income Tax Regs., adopted in 1978 (the 1978 regulations), T.D. 7549, 1978-1 C.B. 185, 187, was invalid. In our prior opinion, we held that the 1978 regulations were an impermissible interpretation of the statutes they purported to interpret. The 1978 regulations govern…
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