Legal Opinion

Lincoln Sav. & Loan Asso. v. Commissioner

United States Tax Court

Decided October 21, 1968No. Docket No. 325-67Published

Petitioner, a California savings and loan association, insures the accounts of its depositors with the Federal Savings and Loan Insurance Corporation (FSLIC). It pays regular annual premiums for such insurance coverage, which are deductible. Such premiums are part of FSLIC's gross income, available to meet all current expenses and losses, and to the extent not so used are transferred to FSLIC's "Primary Reserve" to meet losses of future years.

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Petitioner, a California savings and loan association, insures the accounts of its depositors with the Federal Savings and Loan Insurance Corporation (FSLIC). It pays regular annual premiums for such insurance coverage, which are deductible. Such premiums are part of FSLIC's gross income, available to meet all current expenses and losses, and to the extent not so used are transferred to FSLIC's "Primary Reserve" to meet losses of future years. Since 1962, petitioner has also been required to make additional annual payments "in the nature of * * * [prepayments] with respect to future…

1Opinion of the Court

Lincoln Savings & Loan Association, Petitioner v. Commissioner of Internal Revenue, Respondent

Lincoln Sav. & Loan Asso. v. Commissioner

Docket No. 325-67

United States Tax Court

51 T.C. 82; 1968 U.S. Tax Ct. LEXIS 44;

October 21, 1968, Filed

Decision will be entered for the respondent.

Petitioner, a California savings and loan association, insures the accounts of its depositors with the Federal Savings and Loan Insurance Corporation (FSLIC). It pays regular annual premiums for such insurance coverage, which are deductible. Such premiums are part of FSLIC's gross income, available to meet all…

2Cases cited26 opinions

  1. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  2. Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  3. Higginbotham-Bailey-Logan Co. v. CommissionerUnited States Board of Tax Appeals · 1927
  4. Commissioner of Internal Revenue v. Boylston Market Ass'nCourt of Appeals for the First Circuit · 1942
  5. Spring Canyon Coal Co. v. Commissioner of Int. Rev.Court of Appeals for the Tenth Circuit · 1930

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