- 9 - Pinellas County (Pinellas). Thereafter, Pinellas became a subsidiary of Barnett and a member of its consolidated group for Federal income tax purposes. Pinellas’s board of directors consisted of the current directors of Barnett Bank of Pinellas County, N.A., and Home Federal. In addition, Alfred T. May, the president and chief executive officer of Home Federal, served as the president and chief operating officer of Pinellas. Pinellas also continued to use all employees in the combined organization. Pinellas’s deposits were insured by the FDIC and, after FIRREA, by the BIF. Bad Debt Reserve Method of Accounting After their acquisitions by Barnett, Southwest and Pinellas were members of Barnett's consolidated group for Federal income tax purposes. Barnett timely filed (pursuant to extensions) a Form 1120, U.S. Corporation Income Tax Return, for each of its taxable years 1986 through 1994. For all relevant years, petitioner used a fiscal year ended December 31. For each of the taxable years in issue, Barnett took the position that Southwest and Pinellas qualified as "domestic building and loan associations" within the meaning of section 7701(a)(19); as a result, Barnett claimed a deduction for Southwest’s and Pinellas’s bad debts based on the reserve method of accounting under former section 593. Barnett attached thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011