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FIRST NATIONAL BANK v. COMMISSIONER

Docket No. 44642.

22 T.C. 209 (1954)

FIRST NATIONAL BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 30, 1954.

Attorney(s) appearing for the Case

William W. Johnston, C. P. A., for the petitioner.

James T. Lodge, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $502.96 in income tax of the petitioner for 1949. The only issue for decision is whether the petitioner is entitled to a recovery exclusion of $688.73 under section 22 (b) (12), Internal Revenue Code, resulting from a recovery on a debt previously charged off. The facts have been presented by a stipulation which is adopted as the findings of fact.

The petitioner filed its...

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