Legal Opinion

North-Western Trust & Sav. Bank v. Commissioner

United States Board of Tax Appeals

Decided July 29, 1930No. Docket No. 31128Published

1. In making loans upon real estate security the petitioner charged and deducted from the face of the loans a commission which was entered upon its books of account and returned as taxable income of the year in which the loan was made. At the close of each year the petitioner had on hand a large amount of mortgage notes and bonds which it had not sold to its clients. The petitioner kept its books of account and made its income-tax returns upon the accrual basis.

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1. In making loans upon real estate security the petitioner charged and deducted from the face of the loans a commission which was entered upon its books of account and returned as taxable income of the year in which the loan was made. At the close of each year the petitioner had on hand a large amount of mortgage notes and bonds which it had not sold to its clients. The petitioner kept its books of account and made its income-tax returns upon the accrual basis. Held that the commissions shown as income upon its books of account and in its returns constituted taxable income of the year in…

1Opinion of the Court

NORTH-WESTERN TRUST & SAVINGS BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

North-Western Trust & Sav. Bank v. Commissioner

Docket No. 31128.

United States Board of Tax Appeals

20 B.T.A. 365; 1930 BTA LEXIS 2135;

July 29, 1930, Promulgated

1. In making loans upon real estate security the petitioner charged and deducted from the face of the loans a commission which was entered upon its books of account and returned as taxable income of the year in which the loan was made. At the close of each year the petitioner had on hand a large amount of mortgage notes and bonds which it had…

2Cases cited1 opinion

  1. North-Western Trust & Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1930

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