Pacific First Federal Sav. & Loan Asso. v. Commissioner
United States Tax Court
Petitioner was in the business of making loans for the purchase or construction of commercial and residential real estate. Held, "loan origination fees," which were variable percentages of the face amount of loans, constituted interest and not compensation for services rendered.
1Opinion of the Court
Pacific First Federal Savings & Loan Association, Petitioner v. Commissioner of Internal Revenue, Respondent
Pacific First Federal Sav. & Loan Asso. v. Commissioner
Docket No. 6114-80
United States Tax Court
79 T.C. 512; 1982 U.S. Tax Ct. LEXIS 36; 79 T.C. No. 33;
September 23, 1982, Filed
Decision will be entered under Rule 155.
Petitioner was in the business of making loans for the purchase or construction of commercial and residential real estate. Held, "loan origination fees," which were variable percentages of the face amount of loans, constituted interest and not compensation for services…
2Cases cited8 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Goodwin v. CommissionerUnited States Tax Court · 1980
- Wilkerson v. CommissionerUnited States Tax Court · 1978
- L-R Heat Treating Co. v. CommissionerUnited States Tax Court · 1957
- Blitzer v. United StatesUnited States Court of Claims · 1982
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