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
The First Pennsylvania Banking and Trust Company, Petitioner v. Commissioner of Internal Revenue, Respondent
First Pennsylvania Banking & Trust Co. v. Commissioner
Docket No. 1215-68
United States Tax Court
56 T.C. 677; 1971 U.S. Tax Ct. LEXIS 104;
June 30, 1971, Filed
Decision will be entered under Rule 50.
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…
2Cases cited20 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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