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HOME GROUP, INC. v. COMMISSIONER

Docket No. 17739-82.

91 T.C. 265 (1988)

THE HOME GROUP, INC., AS AGENT UNDER THE PROVISIONS OF TREASURY REGULATION SECTION 1.1502-77(d) FOR CITY INVESTING COMPANY AND THE CONSOLIDATED GROUP OF WHICH CITY INVESTING COMPANY WAS THE COMMON PARENT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 18, 1988.

Attorney(s) appearing for the Case

John S. Breckinridge, Jr., and F. Brook Voght, for the petitioner.

David N. Brodsky and Robert J. Foley, for the respondent.

OPINION

GERBER, Judge:

This controversy was generated by the parties' differing computations under Rule 155,1 pursuant to our opinion rendered in this case.2 The Rule 155 controversy centered about section 593, which places limits upon the addition to the reserve for bad debts of certain savings banks. See sec. 593(b)(1). During the taxable year in question, petitioner's consolidated subsidiary...

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