First Pennsylvania Banking & Trust Co. v. Commissioner
United States Tax Court
As the result of one transaction petitioner acquired (1) a loan-servicing business as a going concern, (2) that business's rights to service existing loans of various lending institutions, (3) an opportunity to service future loans of such institutions, (4) an opportunity to utilize escrow funds associated with the existing loans, and (5) an opportunity to utilize escrow funds associated with future loans that petitioner might service for the lending institutions.
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As the result of one transaction petitioner acquired (1) a loan-servicing business as a going concern, (2) that business's rights to service existing loans of various lending institutions, (3) an opportunity to service future loans of such institutions, (4) an opportunity to utilize escrow funds associated with the existing loans, and (5) an opportunity to utilize escrow funds associated with future loans that petitioner might service for the lending institutions. Held: The rights to service existing loans and the opportunity to utilize escrow funds associated therewith may be separately…
1Opinion of the Court
FoeRestee, Judge-.
Respondent has determined deficiencies in petitioner’s corporate income tax in the years and for tbe amounts as follows:
Year Taw
1959 _$203,405.12
1960 _ 6, 448. 29
1961 _ 212,573.83
1962 _ 367,400.51
1963 _ 60,357.17
Concessions having been made, the only issue remaining for decision pertains to the years 1961, 1962, and 1963 and involves the extent to which petitioner may amortize the purchase price of a mortgage servicing business.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulations and exhibits attached thereto are incorporated herein by this reference.
The…
2Cases cited19 opinions
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Compañia General De Tabacos De Filipinas v. Collector of Internal RevenueSupreme Court of the United States · 1927
- Michaels v. CommissionerUnited States Tax Court · 1949
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
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3Cited by23 opinions
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- Banc One Corp. v. CommissionerUnited States Tax Court · 1985
- Massey-Ferguson, Inc. v. CommissionerUnited States Tax Court · 1972
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