Iowa-Des Moines Nat'l Bank v. Commissioner
United States Tax Court
In 1968, petitioner banks implemented a consumer credit card plan as part of their banking operations. Held, the expenditures attributable thereto, with the exception of the initial $ 10,000 membership fee assessed each bank, are currently deductible as ordinary and necessary business expenses under sec. 162, I.R.C. 1954. First Security Bank of Idaho, N.A. v. Commissioner, 63 T.C. 644 (1975), on appeal (9th Cir., Sept. 7, 1976), followed.
1Opinion of the Court
Fay, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Docket No. Petitioner Year Deficiency
8572-75 Iowa-Des Moines National Bank.. 1968 $102,600.85
1969 275,971.21
1970 1,789.28
8573-751 The United States National Bank of Omaha. 1968 54,539.97
1969 64,654.95
1970 4,696.60
These cases were consolidated for purposes of trial, briefing, and opinion.
Concessions having been made, we are to decide whether certain expenditures related to petitioners’ participation in the Master Charge credit card system are deductible as ordinary and necessary business expenses…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- United States v. Mississippi Chemical Corp.Supreme Court of the United States · 1972
- The Colorado Springs National Bank, a National Banking Association v. United StatesCourt of Appeals for the Tenth Circuit · 1974
7 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Seligman v. CommissionerUnited States Tax Court · 1985
- Ellis Banking Corporation v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1982
- Pnc Bancorp, Inc., Successor to First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16002) Pnc Bancorp, Inc., Transferee of Assets of First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16003) Pnc Bancorp, Inc., Successor to United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16109) Pnc Bancorp, Inc., Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16110) Pnc Bancorp, Inc., as (I) Successor to First National Pennsylvania Corporation, (Ii) Transferee of Assets of First National Pennsylvania Corporation, (Iii) Successor to United Federal Bancorp, Inc., and Subsidiaries, and (Iv) Transferee of Assets of United Federal Bancorp, Inc., and SubsidiariesCourt of Appeals for the First Circuit · 2000
- Iowa-Des Moines National Bank v. Commissioner of Internal Revenue, United States National Bank of Omaha v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1979
- Norwest Corp. v. CommissionerUnited States Tax Court · 1999
25 more not listed; retrieve them via the Exa API.