Investors Discount Corp. v. Commissioner
United States Tax Court
Petitioner owned debt obligations, subject to repurchase undertakings on the part of third parties. Held, that, in the absence of evidence that the repurchase undertakings would not be honored, petitioner is not entitled to additions to its bad debt reserve with respect to such debt obligations.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax for the taxable years 1962 and 1963 in the amounts of $1,257.87 and $7,272.94, respectively. The sole issue for our determination is whether petitioner made reasonable additions to its reserve for bad debts in 1961, 1962, and 1963 within the meaning of section 166(c).1
findings of fact
Some of the facts have been stipulated and are found accordingly.
Petitioner is an Ohio corporation and had its principal place of business in Cincinnati, Ohio, at the time of filing the petition herein.
Petitioner filed its…
2Cases cited16 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
- Underhill v. CommissionerUnited States Tax Court · 1966
11 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
- Valmont Industries, Inc. v. CommissionerUnited States Tax Court · 1980
- Citizens' Acceptance Corporation, a Dissolved Corporation Continued by Statute for Purposes of Suit v. United StatesCourt of Appeals for the Third Circuit · 1972
- Beneficial Corporation and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Massachusetts Business Development Corp. v. CommissionerUnited States Tax Court · 1969
12 more not listed; retrieve them via the Exa API.