Legal Opinion

Sec. Bank Minn. v. Comm'r

United States Tax Court

Decided January 21, 1992No. Docket No. 7552-90Published

P, a commercial bank, routinely made short-term loans to customers in the ordinary course of its business. Interest income, as well as other items of income and expense, were reported on a cash basis under sec. 446, I.R.C.Held, sec. 1281 does not require P to accrue interest on short-term loans made to its customers in the ordinary course of its business.

1Opinion of the Court

Security Bank Minnesota, Petitioner v. Commissioner of Internal Revenue, Respondent

Sec. Bank Minn. v. Comm'r

Docket No. 7552-90

United States Tax Court

98 T.C. 33; 1992 U.S. Tax Ct. LEXIS 5; 98 T.C. No. 4; 71 A.F.T.R.2d (RIA) 1959;

January 21, 1992, Filed

Decision will be entered for petitioner.

P, a commercial bank, routinely made short-term loans to customers in the ordinary course of its business. Interest income, as well as other items of income and expense, were reported on a cash basis under sec. 446, I.R.C.Held, sec. 1281 does not require P to accrue interest on short-term loans made to its…

Also in this document: Dissent.

2Cases cited5 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
  3. United States v. PriceSupreme Court of the United States · 1960
  4. Sec. Bank Minn. v. Comm'rUnited States Tax Court · 1992
  5. Barnes Transp. Co. v. CommissionerUnited States Tax Court · 1950

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