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opinion, the Court of Appeals for the Eighth Circuit
also made an extensive analysis of the same factors.
One of the judges on the Court of Appeals panel
dissented.
No purpose would be served by repeating the
statutory analysis that lead this Court and the Court
of Appeals to decide that section 1281(a)(2) does not
apply to loans made by banks in the ordinary course of
business. Suffice it to say that this matter has been
thoroughly considered and decided. The doctrine of
stare decisis generally requires that we follow the
holding of a previously decided case, absent special
justification. This doctrine is of particular
importance when the antecedent case involves statutory
construction. Hesselink v. Commissioner, 97 T.C. 94,
99-100 (1991). While respondent has skillfully
rearticulated his arguments in support of a different
interpretation of the statute, we find nothing therein
that would cause us to refrain from applying the
doctrine of stare decisis with respect to the section
1281(a)(2) issue. [Fn. ref. omitted.]
We agree, and decline to overrule Security Bank Minn. v.
Commissioner, supra, with respect to this issue. Accordingly, we
hold that section 1281(a)(2), as interpreted by Security Bank
Minn. and applied in Security State Bank v. Commissioner, supra,
does not require the accrual of interest with respect to the
short-term consumer, commercial, and agricultural loans made by
IFNB to its customers.
IV. Respondent's Second Argument: Section 1281(a)(1) and OID
Respondent argues in the alternative that, even if we follow
Security Bank Minn. v. Commissioner, supra, the short-term
obligation rules should still be applied to IFNB's loans, CD's,
and time deposits, for the following reason. Respondent asserts
in this case that IFNB's loans and deposits were issued by the
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