First Nat'l Bank v. Commissioner
United States Tax Court
Petitioner, a national banking association, administers numerous trusts through its trust department. In administering the trusts, the said department makes cash payments on their behalf. Each cash payment is charged either to the principal or to the income account of the trust on behalf of which it is made.
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Petitioner, a national banking association, administers numerous trusts through its trust department. In administering the trusts, the said department makes cash payments on their behalf. Each cash payment is charged either to the principal or to the income account of the trust on behalf of which it is made. If a payment exceeds the balance in the account to be charged, the trust department may nonetheless make the payment, obtaining the funds necessary to cover the excess from petitioner's commercial loan department. Such a transaction is undertaken only if petitioner's responsible officers…
1Opinion of the Court
Fay, Judge:
Respondent determined a deficiency of $419,253.17 in the Federal income tax of petitioner, the First National Bank of Chicago, for the year 1968. Certain concessions having been made, it remains for us to decide if respondent properly disallowed a portion of the deduction claimed by petitioner for an addition to its reserve for bad debts. Sec. 166(c), I.R.C. 1954.1
FINDINGS OF FACT
Many of the facts pertinent to this case have been stipulated and are so found.
Petitioner is a national banking association. It filed a U.S. corporation income tax return for the year in issue with the…
2Cases cited8 opinions
- Commissioner v. ConnellySupreme Court of the United States · 1949
- First American National Bank of Nashville v. United StatesCourt of Appeals for the First Circuit · 1972
- Pullman Trust & Savings Bank v. United StatesDistrict Court, N.D. Illinois · 1963
- Pullman Trust & Savings Bank, an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1964
- North Carolina National Bank v. The United StatesUnited States Court of Claims · 1965
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3Cited by2 opinions
- The First National Bank of Chicago v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1977
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1975