Barnett Banks, Inc. & Subsidiaries - Page 10




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          savings and loan qualifications tests for Southwest and Pinellas            
          to each of the returns for the years in issue.                              
               On December 11, 1997, a notice of deficiency was issued for            
          petitioner’s taxable years 1983 through 1987.  In this notice of            
          deficiency, respondent proposed adjustments to Barnett's taxable            
          income to reverse Southwest's and Pinellas’s bad debt reserves,             
          which were calculated under section 593, in the following amounts           
          and taxable years:                                                          
               Year       Pinellas      Southwest         Total                       
          12/31/86       –-        $15,848,132         $15,848,123                    
          12/31/87       $37,408,897    –-        37,408,897                          
               On December 22, 1997, a notice of deficiency was issued for            
          petitioner’s taxable years 1988 through 1994.  In this notice of            
          deficiency, respondent disallowed Barnett's deductions claimed              
          for Southwest's and Pinellas’s bad debt reserves under section              
          593 in the following amounts and taxable years:                             
                    Year      Pinellas     Southwest     Total                        
          12/31/88  ($1,597,859)   $2,006,462     $408,603                            
               12/31/89       2,369,843       934,603    3,304,446                    
               12/31/90   (1,713,509)       20,778   (1,692,731)                      
          12/31/91            2,196,073      (192,019)   2,004,054                    
          12/31/92    1,854,512     1,544,816    3,399,328                            
          12/31/93            643,535      (914,984)    (271,449)                     
          12/31/94            599,905      (151,366)     448,539                      
          Regulation and Supervision                                                  
               During the taxable years 1986 through 1994, chapter 655 of             
          title XXXVIII of the Florida Code provided the Florida Department           







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Last modified: May 25, 2011