Bell Fed. Sav. & Loan Ass'n v. Commissioner
United States Tax Court
P, an accrual method taxpayer, is a savings and loan association who made original home mortgage loans to borrowers. P recognized the prepaid interest it received from the loans (points) over an 8-year period using a half-year convention even though the borrowers brought to closing separate funds sufficient to cover both closing costs and points. Further, P incurred net operating losses (NOLs) during its 1983 and 1984 taxable years.
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P, an accrual method taxpayer, is a savings and loan association who made original home mortgage loans to borrowers. P recognized the prepaid interest it received from the loans (points) over an 8-year period using a half-year convention even though the borrowers brought to closing separate funds sufficient to cover both closing costs and points. Further, P incurred net operating losses (NOLs) during its 1983 and 1984 taxable years. P carried the NOLs back to its 1978 taxable year without recalculating the addition to its bad debt reserve for 1978 to reflect the carried back NOLs. HELD,…
1Opinion of the Court
BELL FEDERAL SAVINGS AND LOAN ASSOCIATION AND SUBSIDIARY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bell Fed. Sav. & Loan Ass'n v. Commissioner
Docket No. 11822-89
United States Tax Court
T.C. Memo 1991-368; 1991 Tax Ct. Memo LEXIS 417; 62 T.C.M. (CCH) 376; T.C.M. (RIA) 91368;
August 7, 1991, Filed
Decision will be entered under Rule 155.
P, an accrual method taxpayer, is a savings and loan association who made original home mortgage loans to borrowers. P recognized the prepaid interest it received from the loans (points) over an 8-year period using a half-year convention even…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- The Franklin Life Insurance Company v. United StatesCourt of Appeals for the Seventh Circuit · 1968
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