Legal Opinion

Colonial Sav. Asso. v. Commissioner

United States Tax Court

Decided November 26, 1985No. Docket No. 25477-82Published

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 Depositors were entitled to withdraw the interest, but incurred a penalty if principal was withdrawn before maturity of the certificate.

Read the full summary

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 Depositors were entitled to withdraw the interest, but incurred a penalty if principal was withdrawn before maturity of the certificate.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

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  3. Commissioner v. JacobsonSupreme Court of the United States · 1949
  4. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  5. Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926

21 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