Columbia State Sav. Bank v. Commissioner
United States Board of Tax Appeals
The petitioner made real estate or mortgage loans during 1921 and 1922, bearing interest at a specified rate. In addition to the interest, a commission was charged and deducted from the face of each loan, and, in the event of payment before maturity, no rebate was made to the borrower of any part of the commission. The petitioner kept its books upon an accrual basis.
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The petitioner made real estate or mortgage loans during 1921 and 1922, bearing interest at a specified rate. In addition to the interest, a commission was charged and deducted from the face of each loan, and, in the event of payment before maturity, no rebate was made to the borrower of any part of the commission. The petitioner kept its books upon an accrual basis. Held, that the total amount of commissions on loans so made in the respective years constituted taxable income for such years. Chicago Acceptance Co.,12 B.T.A. 150, distinguished.
1Opinion of the Court
*220OPINION.
Teammell:
In the original petition filed under Docket No. 14831, the petitioner sought the redetermination of its tax liability for the calendar years 1920 and-1921. No deficiency, however, was asserted for 1920, and we have no jurisdiction for that year. See Revenue Act of 1926, section 274 (g); Cornelius Cotton Mills, 4 B. T. A. 255; *221Belridge Oil Co., 11 B. T. A. 127; D. L. Blackstone, Administrator, 12 B. T. A. 456. Accordingly, this appeal, in so far as it purports to involve the calendar year 1920, is dismissed.
With respect to the deficiency in tax determined by the respondent for…
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