PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation v. Commissioner

110 T.C. No. 27

UNITED STATES TAX COURT PNC BANCORP, INC., SUCCESSOR TO FIRST NATIONAL PENNSYLVANIA CORPORATION, ET AL.,1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 16002-95, 16003-95, Filed June 8, 1998. 16109-96, 16110-96. As a result of mergers, P succeeded to the interests of two banks. During the years in issue, the banks' primary source of revenue was interest charged on loans. In the process of making loans, the banks incurred costs for property reports, credit reports, appraisals, recording security interests, and salaries and benefits to bank employees. The…