United Surgical Steel Co. v. Commissioner
United States Tax Court
1. The petitioner claimed deductions for additions to its reserve for bad debts for guaranteed debt obligations in its returns filed for its taxable years ending before Oct. 22, 1965. The petitioner initially agreed to the respondent's determination that disallowed the claimed deductions, however, it subsequently claimed that it was entitled to maintain a reserve for guaranteed debt obligations pursuant to sec. 2 of Pub.
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1. The petitioner claimed deductions for additions to its reserve for bad debts for guaranteed debt obligations in its returns filed for its taxable years ending before Oct. 22, 1965. The petitioner initially agreed to the respondent's determination that disallowed the claimed deductions, however, it subsequently claimed that it was entitled to maintain a reserve for guaranteed debt obligations pursuant to sec. 2 of Pub. L. 89-722. Held, that the petitioner is not entitled to claim the benefits of Pub. L. 89-722 for its taxable years ended Nov. 30, 1962 and 1963, as the assessment of a…
1Opinion of the Court
OPINION
Issue Í. Reserve for Bad Debts for Guaranteed Debt Obligations
In its returns for the .taxable years ended November 30,1962,1963, and 1964, tbe petitioner deducted additions to its reserve for bad debts on .account of conditional sales contracts sold to United Discount Co., Inc., payment of which was guaranteed by the petitioner. In the examination of those returns, the deductions of the additions to the reserve were disallowed by the respondent and the resulting deficiencies were assessed on April 1,1966.
In the meanwhile, on February 16, 1966, the petitioner filed an Application for…
2Cases cited10 opinions
- Leuthesser v. CommissionerUnited States Tax Court · 1952
- Bouchey v. CommissionerUnited States Tax Court · 1953
- Elmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- Investors Discount Corp. v. CommissionerUnited States Tax Court · 1967
- Town & Country Food Co. v. CommissionerUnited States Tax Court · 1969
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- Mathers v. CommissionerUnited States Tax Court · 1972
- Mathers v. CommissionerUnited States Tax Court · 1972
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