ANNAPOLIS FEDERAL SAVINGS AND LOAN ASSOCIATION v. COMMISSIONER

Docket No. 4100-70

31 T.C.M. 1206 (1972)

T.C. Memo. 1972-243

Annapolis Federal Savings and Loan Association v. Commissioner.

United States Tax Court.

Filed December 6, 1972.


Attorney(s) appearing for the Case

D.L. Mitchell, 3900 Wisconsin Ave., Washington, D.C. and Thomas A. O'Neil, for the petitioner. Randolph D. Mason, for the respondent.


Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a deficiency in petitioner's 1967 Federal income tax in the amount of $23,844.07.

Petitioner claimed a $169,334 net operating loss deduction in its corporate income tax return for the calendar year 1967. Respondent disallowed $115,113 of the deduction, representing deductions claimed for additions to a bad debt reserve for the calendar years 1964, 1965 and 1966 of an acquired...

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