Legal Opinion

Peoples Bank & Trust Co. v. Commissioner

United States Tax Court

Decided August 19, 1968No. Docket No. 2693-67PublishedCited by 41 opinions

Pursuant to its longstanding and generally accepted accrual method of accounting, Peoples Bank deducted as an interest expense the balance of a reserve existing at the end of each year in issue which reflected the estimated portion of actual interest credits to be made to savings accounts on May 1 of the following year which were allocable to the months of November and December of the taxable year.

Read the full summary

Pursuant to its longstanding and generally accepted accrual method of accounting, Peoples Bank deducted as an interest expense the balance of a reserve existing at the end of each year in issue which reflected the estimated portion of actual interest credits to be made to savings accounts on May 1 of the following year which were allocable to the months of November and December of the taxable year. Held, since there existed no fixed and certain interest liability on the savings deposits as of Dec. 31, no interest expense was properly accruable at that time. Held, further, respondent initiated…

1Opinion of the Court

DawsoN, Judge:

Respondent determined the following income tax deficiencies against the petitioner:

Year Deficiency

1962 _$10,856.96

1963 _ 2,476.99

1964 _ 3,788.80

By amended answer respondent claims additional deficiencies of $169.55 for 1962 and $100 for 1964. Certain adjustments have not been placed in controversy by petitioner. The principal issue for decision is whether petitioner is entitled to interest expense deductions for amounts which, under its regular and longstanding method of accounting, were accrued as expenses in the months of November and December of each of the years in issue. If…

2Cases cited9 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Lucas v. American Code Co.Supreme Court of the United States · 1930
  3. Brown v. HelveringSupreme Court of the United States · 1934
  4. Weiss v. WeinerSupreme Court of the United States · 1929
  5. Niles Bement Pond Co. v. United StatesSupreme Court of the United States · 1930

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

3Cited by41 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Sandor v. CommissionerUnited States Tax Court · 1974
  3. Coors v. CommissionerUnited States Tax Court · 1973
  4. Resnik v. CommissionerUnited States Tax Court · 1976
  5. Schuster's Express, Inc. v. CommissionerUnited States Tax Court · 1976

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API