San Antonio Sav. Asso. v. Commissioner
United States Tax Court
Petitioner, a regulated savings and loan institution, simultaneously sold and purchased loan participations in a three-cornered transaction with two other unrelated savings and loan institutions. Petitioner deducted the difference between the remaining principal balances of the participation interests sold and the amount of cash received in the transaction. On Petitioner's Motion for Summary Judgment, held, petitioner realized and may recognize losses on the transaction.
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Petitioner, a regulated savings and loan institution, simultaneously sold and purchased loan participations in a three-cornered transaction with two other unrelated savings and loan institutions. Petitioner deducted the difference between the remaining principal balances of the participation interests sold and the amount of cash received in the transaction. On Petitioner's Motion for Summary Judgment, held, petitioner realized and may recognize losses on the transaction. Cottage Savings Assoc. v. Commissioner, 90 T.C. (Mar. 14, 1988), and Federal National Mortgage Assoc. v. Commissioner, 90…
1Opinion of the Court
SAN ANTONIO SAVINGS ASSOCIATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
San Antonio Sav. Asso. v. Commissioner
Docket No. 47016-86.
United States Tax Court
T.C. Memo 1988-204; 1988 Tax Ct. Memo LEXIS 225; 55 T.C.M. (CCH) 813; T.C.M. (RIA) 88204;
May 5, 1988; As amended May 6, 1988
Petitioner, a regulated savings and loan institution, simultaneously sold and purchased loan participations in a three-cornered transaction with two other unrelated savings and loan institutions. Petitioner deducted the difference between the remaining principal balances of the…
2Cases cited3 opinions
- Hanlin v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1939
- Hanlin v. CommissionerUnited States Board of Tax Appeals · 1938
- Widener, Trust No. 5 v. CommissionerUnited States Tax Court · 1983
3Cited by3 opinions
- San Antonio Savings Association and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1989
- Cottage Savings Association v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1990
- First Federal Savings and Loan Association of Temple v. United StatesCourt of Appeals for the First Circuit · 1989