Lincoln Sav. & Loan Asso. v. Commissioner
United States Tax Court
Petitioner, a California savings and loan association, insures the accounts of its depositors with the Federal Savings and Loan Insurance Corporation (FSLIC). It pays regular annual premiums for such insurance coverage, which are deductible. Such premiums are part of FSLIC's gross income, available to meet all current expenses and losses, and to the extent not so used are transferred to FSLIC's "Primary Reserve" to meet losses of future years.
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Petitioner, a California savings and loan association, insures the accounts of its depositors with the Federal Savings and Loan Insurance Corporation (FSLIC). It pays regular annual premiums for such insurance coverage, which are deductible. Such premiums are part of FSLIC's gross income, available to meet all current expenses and losses, and to the extent not so used are transferred to FSLIC's "Primary Reserve" to meet losses of future years. Since 1962, petitioner has also been required to make additional annual payments "in the nature of * * * [prepayments] with respect to future…
1Opinion of the Court
OPINION
Batovi, Judge:
Petitioner, a savings and loan association licensed by the State of California and doing business in the Los Angeles area, has since 1938 insured the savings accounts of its depositors with the Federal Savings and Loan Insurance Corporation (the “FSLIC”), pursuant to the provisions of title IV of the National Housing Act, as amended. (12 U.S.C. sec. 1724 et seg.) It pays an annual “premium for such insurance” in an amount equal to i/12 of 1 percent of the total amount of all its savings accounts and creditor obligations, as provided in section 1727(b) (1). Since 1962, as…
2Cases cited25 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Higginbotham-Bailey-Logan Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Commissioner of Internal Revenue v. Boylston Market Ass'nCourt of Appeals for the First Circuit · 1942
- Spring Canyon Coal Co. v. Commissioner of Int. Rev.Court of Appeals for the Tenth Circuit · 1930
20 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Boyer v. CommissionerUnited States Tax Court · 1977
- Lincoln Savings and Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Estate of Morris v. CommissionerUnited States Tax Court · 1971
- Brownholtz v. CommissionerUnited States Tax Court · 1978
15 more not listed; retrieve them via the Exa API.