Columbia State Sav. Bank v. Commissioner of Int. Rev.

ALSCHULER, Circuit Judge.

The petitioner sought redetermination of its federal income and profits taxes for the years 1921 and 1922. Petitioner was a banker, a large part of its business being the making of real estate loans, and for these loans taking from the borrower notes with real estate mortgage security, charging the borrower not only interest on the loan, but a commission for its service in making the loan. This commission was usually deducted from the amount of the loan, and the balance paid the borrower. As opportunity presented, petitioner would sell the notes. For all the time in…