Security Bank Minnesota v. Commissioner of Internal Revenue Service

MAGILL, Circuit Judge.

This case presents an issue of first impression: whether § 1281 of the Internal Revenue Code, which requires certain taxpayers to accrue discount and interest income on certain short-term obligations, requires a commercial bank, otherwise reporting its income on the cash basis, to report interest income on short-term loans made to borrowers in the ordinary course of business as it accrues. The tax court held that § 1281 did not apply to such loans. We agree, and affirm.

I. BACKGROUND

A. Factual Background

This case involves an asserted deficiency in Security Bank’s federal…