Legal Opinion

Columbia State Sav. Bank v. Commissioner

United States Board of Tax Appeals

Decided November 22, 1934No. Docket No. 45261PublishedCited by 3 opinions

Where books of taxpayer engaged in the making of interestbearing real estate mortgage loans are kept on an accrual basis, commissions or discounts deducted from the principal are income in the year the loans are made.

1Opinion of the Court

*687OPINION.

McMahon:

The question to be determined is whether commissions or discounts deducted from the principal or face of real estate mortgage loans are income in the year in which the loans are made, the books of account being kept on an accrual basis.

The petitioner included in taxable income for 1927 all commissions or discounts on loans sold or otherwise disposed of during 1927 whether made in 1927 or prior thereto. It contends that under the facts in this proceeding, while admittedly on an accrual basis, it did not derive income from the deduction of discount or commissions from the face…

2Cited by3 opinions

  1. Columbia State Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Motors Secs. Co. v. CommissionerUnited States Tax Court · 1952
  3. Vancoh Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1936

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