Legal Opinion

Richmond Hill Sav. Bank v. Commissioner

United States Tax Court

Decided March 13, 1972No. Docket Nos. 5777-69, 141-70Published

Petitioners, mutual savings banks, made loans secured by real estate. Pursuant to the mortgage instruments and State law, petitioners required mortgagors to advance escrow deposits for the payment of real estate taxes, special assessments, and insurance premiums as they came due, which were received by petitioners and commingled with their general funds.

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Petitioners, mutual savings banks, made loans secured by real estate. Pursuant to the mortgage instruments and State law, petitioners required mortgagors to advance escrow deposits for the payment of real estate taxes, special assessments, and insurance premiums as they came due, which were received by petitioners and commingled with their general funds. Petitioners computed the 3-percent additions to their reserves for bad debts under sec. 593(b)(3), I.R.C. 1954, based on their "qualifying real property loans," unreduced by the amount of mortgagor escrow deposits. Sec. 593(e) requires that…

1Opinion of the Court

Richmond Hill Savings Bank, Petitioner v. Commissioner of Internal Revenue, Respondent; College Point Savings Bank, Petitioner v. Commissioner of Internal Revenue, Respondent

Richmond Hill Sav. Bank v. Commissioner

Docket Nos. 5777-69, 141-70

United States Tax Court

57 T.C. 738; 1972 U.S. Tax Ct. LEXIS 167;

March 13, 1972, Filed

Decisions will be entered under Rule 50.

Petitioners, mutual savings banks, made loans secured by real estate. Pursuant to the mortgage instruments and State law, petitioners required mortgagors to advance escrow deposits for the payment of real estate taxes, special…

2Cases cited9 opinions

  1. Barson v. . MulliganNew York Court of Appeals · 1908
  2. First Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1963
  3. In Matter of SimonDistrict Court, E.D. New York · 1958
  4. Valerio v. College Point Savings BankNew York Supreme Court · 1965
  5. Cassedy v. Johnstown BankAppellate Division of the Supreme Court of the State of New York · 1936

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