Arcadia Sav. & Loan Asso. v. Commissioner
United States Tax Court
Income -- Bad Debt Reserve -- Restoring Unneeded Balance to Income. -- A reserve for bad debts created by an addition in 1952 under section 23(k)(1) which offset taxable income of a domestic building and loan association was properly restored to income in the later year in which the need for maintaining the reserve ceased.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined deficiencies in income tax of Arcadia Savings and Loan Association (hereinafter called Arcadia) of $95,485.57 for 1954 and $24,227.62 for 1955. He also determined liabilities against the individual petitioners as transferees of Arcadia as follows:
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The stipulation of all of the facts is adopted as the findings of fact.
The only issue for decision is whether $259,931.82 deducted by Arcadia on its 1952 return as an addition to its reserve for bad debts is taxable as income for 1954 and 1955 when the amount was no longer needed as a…
2Cases cited2 opinions
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
3Cited by25 opinions
- Citizens Federal Savings and Loan Association of Cleveland v. United StatesCourt of Appeals for the Federal Circuit · 1961
- Handelman v. CommissionerUnited States Tax Court · 1961
- Bird Management, Inc. v. CommissionerUnited States Tax Court · 1967
- J. E. Hawes Corp. v. CommissionerUnited States Tax Court · 1965
- Burbank Liquidating Corp. v. CommissionerUnited States Tax Court · 1963
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