Security Bank S.S.B. v. Commissioner
United States Tax Court
P, a savings and loan association, acquired by repossession properties securing mortgage loans made by P to the owner-debtors of the properties. At the time P obtained possession of the properties, there was due substantial unpaid interest. P subsequently sold the properties at a gain, and recovered some of the previously unpaid interest.
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P, a savings and loan association, acquired by repossession properties securing mortgage loans made by P to the owner-debtors of the properties. At the time P obtained possession of the properties, there was due substantial unpaid interest. P subsequently sold the properties at a gain, and recovered some of the previously unpaid interest. Held: amounts representing the recovery of unpaid interest on the sale of the foreclosure properties are currently taxable as ordinary income, and are not treated as credits to a bad debt reserve.
1Opinion of the Court
SECURITY BANK S.S.B. & SUBSIDIARIES, f.k.a. SECURITY SAVINGS AND LOAN ASSOCIATION & SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Security Bank S.S.B. v. Commissioner
Docket Nos. 472-92, 15464-93.
United States Tax Court
105 T.C. 101; 1995 U.S. Tax Ct. LEXIS 45; 105 T.C. No. 9;
August 15, 1995, Filed
Decisions will be entered under Rule 155.
P, a savings and loan association, acquired by repossession properties securing mortgage loans made by P to the owner-debtors of the properties. At the time P obtained possession of the properties, there was due substantial unpaid…
2Cases cited8 opinions
- Helvering v. Midland Mutual Life InsuranceSupreme Court of the United States · 1937
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Helvering v. Missouri State Life Ins. Co.Court of Appeals for the Eighth Circuit · 1934
- Allstate Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1977
- Gibraltar Financial Corporation of California, Etc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
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