Sec. Bank Minn. v. Comm'r
United States Tax Court
P, a commercial bank, routinely made short-term loans to customers in the ordinary course of its business. Interest income, as well as other items of income and expense, were reported on a cash basis under sec. 446, I.R.C.Held, sec. 1281 does not require P to accrue interest on short-term loans made to its customers in the ordinary course of its business.
1Opinion of the Court
OPINION
COHEN, Judge:
Respondent determined a deficiency of $48,437.80 in petitioner's Federal income tax for 1986. The issue for decision is whether section 1281 requires petitioner, a commercial bank, to accrue interest on short-term loans made to customers in the ordinary course of its business. If section 1281 does apply to the loans in question, we must determine whether certain of the loans made to petitioner's customers were or were not short-term loans. All section references are to the Internal Revenue Code as in effect for 1986, unless otherwise indicated.
Factual Background
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2Cases cited4 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- United States v. PriceSupreme Court of the United States · 1960
- Barnes Transp. Co. v. CommissionerUnited States Tax Court · 1950
3Cited by7 opinions
- Security State Bank v. CommissionerUnited States Tax Court · 1998
- Security State Bank v. CommissionerCourt of Appeals for the Tenth Circuit · 2000
- Buckeye Countrymark v. CommissionerUnited States Tax Court · 1994
- Buckeye Countrymark v. CommissionerUnited States Tax Court · 1994
- Sec. Bank Minn. v. Comm'rUnited States Tax Court · 1992
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