Commissioner v. Lincoln Savings & Loan Ass'n

This case presents the question whether the “additional premium” paid in 1963 by a state-chartered savings and loan association to the Federal Savings and Loan Insurance Corporation under the compulsion of § 404 (d) of the -National Housing. Act, as amended, 12 U. S. C. *346§ 1727 (d),1 is deductible by the association, for income tax purposes, as an ordinary and necessary business expense under § 162 (a) of the Internal Revenue Code of 1954, 26 U. S. C. §162 (a).'

The Commissioner of Internal Revenue determined a deficiency of $461,454.38 in the 1963 cash basis federal income tax of- Lincoln…