Colonial Sav. Asso. v. Commissioner
United States Tax Court
P, a savings and loan association, was entitled to receive penalties from depositors because of premature withdrawals from their accounts. P generally credited depositors' accounts with compound interest on a daily basis. Depositors were entitled to withdraw the interest, but incurred a penalty if principal was withdrawn before maturity of the certificate.
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P, a savings and loan association, was entitled to receive penalties from depositors because of premature withdrawals from their accounts. P generally credited depositors' accounts with compound interest on a daily basis. Depositors were entitled to withdraw the interest, but incurred a penalty if principal was withdrawn before maturity of the certificate. P contends that the penalties are income from discharge of indebtedness within the meaning of sec. 108, I.R.C. 1954, and may be deferred in accord with Sec. 1017, I.R.C. 1954. Respondent agrees that the penalties are income to P, but…
1Opinion of the Court
Colonial Savings Association and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent
Colonial Sav. Asso. v. Commissioner
Docket No. 25477-82
United States Tax Court
85 T.C. 855; 1985 U.S. Tax Ct. LEXIS 13; 85 T.C. No. 50;
November 26, 1985, Filed
An appropriate order will be entered finding for the respondent on the issue presented in this case
P, a savings and loan association, was entitled to receive penalties from depositors because of premature withdrawals from their accounts. P generally credited depositors' accounts with compound interest on a daily basis. Depositors were…
2Cases cited26 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
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