Continental Illinois Corp. v. Commissioner
United States Tax Court
CINB, a bank wholly owned by petitioner, extended loans to borrowers pursuant to loan agreements which provided an interest rate cap, but called for interest payments at a floating rate which was tied to CINB's prime rate. Under certain conditions, borrowers were entitled at maturity of their loans to repayment of interest to the extent that payments made at the floating rate exceeded payments which would have been made at the cap rate.
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CINB, a bank wholly owned by petitioner, extended loans to borrowers pursuant to loan agreements which provided an interest rate cap, but called for interest payments at a floating rate which was tied to CINB's prime rate. Under certain conditions, borrowers were entitled at maturity of their loans to repayment of interest to the extent that payments made at the floating rate exceeded payments which would have been made at the cap rate. The amount of interest which was subject to repayment by CINB was not included as income on the consolidated returns that petitioner filed for the years in…
1Opinion of the Court
CONTINENTAL ILLINOIS CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Continental Illinois Corp. v. Commissioner
Docket No. 5931-83
United States Tax Court
T.C. Memo 1989-636; 1989 Tax Ct. Memo LEXIS 636; 58 T.C.M. (CCH) 790; T.C.M. (RIA) 89636;
November 28, 1989
CINB, a bank wholly owned by petitioner, extended loans to borrowers pursuant to loan agreements which provided an interest rate cap, but called for interest payments at a floating rate which was tied to CINB's prime rate. Under certain conditions, borrowers were entitled at maturity of their loans to repayment of…
2Cases cited55 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. AndersonSupreme Court of the United States · 1926
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Lucas v. American Code Co.Supreme Court of the United States · 1930
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3Cited by15 opinions
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