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MEMORANDUM OPINION
BEGHE, Judge: This matter is before the Court on
petitioner’s motion for partial summary judgment, as supplemented
(petitioner’s motion), and respondent’s cross-motion for partial
summary judgment under Rule 121.2 Petitioner's principal place
of business was at Portland, Oregon, when it filed its petition.
Relying on Security Bank Minn. v. Commissioner, 98 T.C. 33
(1992), affd. 994 F.2d 432 (8th Cir. 1993), petitioner has moved
for an order that Idaho First National Bank (IFNB), a commercial
bank using the cash method of accounting during 1986, the first
taxable year in issue, is not required by section 1281(a) to
include in its 1986 gross income interest on short-term
obligations (maturing in 1 year or less) that had accrued in 1986
but was not received until 1987.3 Petitioner concedes that, if
and to the extent we grant petitioner's motion, the interest
income in question is properly included in full in petitioner's
2 All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the years in issue (1986-88), unless
otherwise specified.
3 For the purposes of the motion, petitioner has conceded
that 12-month commercial and agricultural loans that are
regularly renewed or rolled over are "short-term" obligations.
Although petitioner's motion states that it does not concede the
point for all purposes, our disposition of the question on such
loans has mooted the point.
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