Centralia Federal Sav. & Loan Asso. v. Commissioner
United States Tax Court
Petitioners, domestic building and loan associations, elected the reserve method for bad debts, and computed their annual additions to reserves under the "percentage of taxable income method." However, instead of crediting such additions to their "reserve for losses on qualifying real property loans," petitioners, during the years in issue, credited such additions to different reserve accounts denominated "Federal Insurance Reserve" and "Reserve for Contingencies."
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Petitioners, domestic building and loan associations, elected the reserve method for bad debts, and computed their annual additions to reserves under the "percentage of taxable income method." However, instead of crediting such additions to their "reserve for losses on qualifying real property loans," petitioners, during the years in issue, credited such additions to different reserve accounts denominated "Federal Insurance Reserve" and "Reserve for Contingencies." These two accounts were considered as constituting together a single reserve account -- the federal insurance reserve -- and were…
1Opinion of the Court
Hall, Judge:
Respondent determined deficiencies in petitioners’ income taxes in the amounts and for the years as follows:
Petitioner Year Deficiency
Centralia Federal Savings & Loan Association_ 1969 $71,011.26
1970 47,023.66
1971 70,213.52
Evergreen First Federal Savings & Loan Association— 1969 52,619.41
1970 41,115.65
1971 38,352.30
These cases were consolidated for trial, briefing, and opinion.
The principal issue in these cases is whether the federal insurance reserve and the reserve for contingencies as maintained by each of the petitioners constitute reserves for bad debts within the…
2Cases cited15 opinions
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- Nash v. United StatesSupreme Court of the United States · 1970
- West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
- Citizens Federal Savings and Loan Association of Cleveland v. United StatesCourt of Appeals for the Federal Circuit · 1961
10 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Centralia Federal Savings & Loan Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1978
- Home Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1983
- Centralia Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1976
- Centralia Federal Savings and Loan Association v. Commissioner of Internal Revenue, Evergreen First Federal Savings and Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1978
- Home Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1983