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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