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MERCHANTS INDUSTRIAL BANK v. C. I. R.

No. 72-1397.

475 F.2d 1063 (1973)

MERCHANTS INDUSTRIAL BANK, a corporation organized and existing under the laws of the State of Colorado, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

Decided March 20, 1973.

Attorney(s) appearing for the Case

Richard R. Helmick, Denver, Colo. (Helmick, Conover & Burkhardt and H. Edward Kluver, Denver, Colo., on the brief), for petitioner-appellant.

Richard Halberstein, Atty., Tax Div., Dept. of Justice (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks and Bruce I. Kogan, Attys., Tax Div., Dept. of Justice, on the brief), for respondent-appellee.

Before BREITENSTEIN, McWILLIAMS, and BARRETT, Circuit Judges.

BREITENSTEIN, Circuit Judge.

In this appeal from the Tax Court, the petitioner-appellant Merchants Industrial Bank contends that the Commissioner of Internal Revenue improperly disallowed portions of the taxpayer's additions to a reserve for bad debts in each of the years 1965, 1966, and 1967. The Tax Court sustained the Commissioner. T.C.Memo.1972-18.

Taxpayer is a bank which makes high-risk loans to persons whose credit does not qualify them for loans from...

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