Legal Opinion

Bonded Mortg. Co. v. Commissioner

United States Board of Tax Appeals

Decided March 20, 1933No. Docket No. 47115Published

1. COMMISSIONS - ACCRUAL BASIS. - The petitioner made real estate mortgage loans bearing interest at a specific rate. In addition to the interest, a commission was charged for making the loan and deducted from the face of each loan at the time the proceeds of the loan were paid over to the borrower. Petitioner kept its books on an accrual basis. Held, the total amount of commissions on loans so made in any particular year is taxable income for that year.

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1. COMMISSIONS - ACCRUAL BASIS. - The petitioner made real estate mortgage loans bearing interest at a specific rate. In addition to the interest, a commission was charged for making the loan and deducted from the face of each loan at the time the proceeds of the loan were paid over to the borrower. Petitioner kept its books on an accrual basis. Held, the total amount of commissions on loans so made in any particular year is taxable income for that year. (Columbia State Savings Bank,15 B.T.A. 219, followed.) 2. DEDUCTIONS. Expenses, including brokerage fees for selling a bond issue, should be…

1Opinion of the Court

THE BONDED MORTGAGE COMPANY OF BALTIMORE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Bonded Mortg. Co. v. Commissioner

Docket No. 47115.

United States Board of Tax Appeals

27 B.T.A. 965; 1933 BTA LEXIS 1271;

March 20, 1933, Promulgated

1. COMMISSIONS - ACCRUAL BASIS. - The petitioner made real estate mortgage loans bearing interest at a specific rate. In addition to the interest, a commission was charged for making the loan and deducted from the face of each loan at the time the proceeds of the loan were paid over to the borrower. Petitioner kept its books on an accrual basis.…

2Cases cited2 opinions

  1. Columbia State Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Bonded Mortg. Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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