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UNITED STATES v. ZIONS SAVINGS AND LOAN ASSOCIATION

No. 7041.

313 F.2d 331 (1963)

UNITED STATES of America, Appellant, v. ZIONS SAVINGS AND LOAN ASSOCIATION, a corporation, Appellee.

United States Court of Appeals Tenth Circuit.

January 2, 1963.

Attorney(s) appearing for the Case

Donald P. Horwitz, Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Meyer Rothwacks, Attorneys, Department of Justice, and William T. Thurman, U. S. Atty., were with him on the brief), for appellant.

Hardin A. Whitney, Jr., Salt Lake City, Utah (Dan T. Moyle of Moyle & Moyle, Salt Lake City, Utah, was with him on the brief), for appellee.

Before PICKETT, BREITENSTEIN and HILL, Circuit Judges.

BREITENSTEIN, Circuit Judge.

The Commissioner of Internal Revenue disallowed certain bad debt deductions claimed by appellee-plaintiff, Zions Savings and Loan Association (taxpayer), in its federal income tax returns. On suit to recover the district court held for the taxpayer. The United States has appealed.

The Revenue Act of 1951 removed the theretofore existing exemption of building and loan associations from federal income tax.1

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