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FIRST CHARTER FINANCIAL CORP. v. U. S.

Nos. 80-5262, 80-5288.

669 F.2d 1342 (1982)

FIRST CHARTER FINANCIAL CORP., Plaintiff-Appellee-Cross-Appellant, v. UNITED STATES of America, Defendant-Appellant-Cross-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 26, 1982.

As Amended April 20, 1982.

Rehearing and Rehearing Denied May 5, 1982.

Attorney(s) appearing for the Case

David E. Carmack, Washington, D.C., argued, for United States; Johnathan S. Cohen, John F. Murray, Michael L. Paup, Richard D. Buik, Washington, D.C., on brief.

Robert J. Wynne, Hill, Wynne, Troop & Meisinger, Los Angeles, Cal., for First Charter Financial Corp.

Before SNEED, KENNEDY and SKOPIL, Circuit Judges.

Rehearing and Rehearing En Banc Denied May 5, 1982.

SKOPIL, Circuit Judge:

FACTS

American Savings & Loan ("American"), a subsidiary of First Charter Financial Corporation, is a domestic building and loan association as defined in I.R.C. § 7701(a)(19). American reported its taxable income on the cash receipts method of accounting and its bad debt deduction under the reserve method. American loaned money secured, either directly or indirectly...

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