Vancoh Realty Co. v. Commissioner

1. Where a loan is extended, the principal of such extended loan including the unpaid balance of principal, representing in part cost and in part unrealized discount, and, in some instances, an increase in principal, the commission charged for the extension being added thereto or paid in cash, the unrealized discount, a part of the principal of the new loan, is income in the taxable year in which such extension is made, taxpayer's books being on the accrual basis. 2. Where taxpayer purchased mortgage loans through brokers at a discount and kept its books on an accrual basis, only the amount…