Legal Opinion

Pacific First Federal Sav. & Loan Asso. v. Commissioner

United States Tax Court

Decided September 23, 1982No. Docket No. 6114-80PublishedCited by 2 opinions

Petitioner was in the business of making loans for the purchase or construction of commercial and residential real estate. Held, "loan origination fees," which were variable percentages of the face amount of loans, constituted interest and not compensation for services rendered.

1Opinion of the Court

Drennen, Judge:

Respondent determined a deficiency of $834,778 in petitioner’s 1976 Federal income tax. Due to concessions, the only issue is whether a "loan origination fee” charged by petitioner in connection with loans it made constituted interest, a charge for services, or, in part, both.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulation of facts and exhibits attached thereto are incorporated herein by reference.

Petitioner Pacific First Federal Savings & Loan Association had its principal office in Tacoma, Wash., at the time it filed the…

2Cases cited7 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Goodwin v. CommissionerUnited States Tax Court · 1980
  3. Wilkerson v. CommissionerUnited States Tax Court · 1978
  4. L-R Heat Treating Co. v. CommissionerUnited States Tax Court · 1957
  5. Blitzer v. United StatesUnited States Court of Claims · 1982

2 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Damer v. Comm'rUnited States Tax Court · 2009
  2. Pacific First Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1982

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