Hudson City Sav. Bank v. Commissioner
United States Tax Court
A mutual savings bank on the accrual basis of accounting declared that interest on deposits for the second 6 months of 1962, 1963, and 1964 was payable on the first business day of January in each of the succeeding years. In practice, depositors were permitted to withdraw the interest on any of the last 3 days of December.
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A mutual savings bank on the accrual basis of accounting declared that interest on deposits for the second 6 months of 1962, 1963, and 1964 was payable on the first business day of January in each of the succeeding years. In practice, depositors were permitted to withdraw the interest on any of the last 3 days of December. Held: (1) The interest is deductible exclusively under sec. 591, I.R.C. 1954, and not sec. 163(a); (2) the interest is deductible in the later, not earlier, years because it was not "withdrawable" until January; and (3) the interest amount at year end is a "liability" and…
1Opinion of the Court
Dawson, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes for the calendar years 1962, 1963, and 1961 in the following amounts;
Year Deficiency
1962 _,_$748,693.10
1963 _ 20, 748. 03
1964 _ 71,903. 53
By amendments to his answer respondent has alleged certain increased deficiencies for these taxable years.
Some adjustments have been agreed to or conceded and can 'be given effect in the Rule 50 computation. The issues remaining for decision are; (1) 'Whether section 591, I.R.C. 1951,1 is the exclusive statutory authority for the allowance of deductions to petitioner, a…
2Cases cited8 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Peoples Bank & Trust Co. v. CommissionerUnited States Tax Court · 1968
- Peoples Bank and Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Shepherd Constr. Co. v. CommissionerUnited States Tax Court · 1969
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Barry v. CommissionerUnited States Tax Court · 1970
- Midwest Sav. Asso. v. CommissionerUnited States Tax Court · 1980
- Barry v. CommissionerUnited States Tax Court · 1970
- Hudson City Sav. Bank v. CommissionerUnited States Tax Court · 1969
- Midwest Sav. Asso. v. CommissionerUnited States Tax Court · 1980
2 more not listed; retrieve them via the Exa API.