U.S. Bancorp, Successor In Interest to West One Bancorp and Subsidiaries, formerly known as Moore Financial Group, Inc. - Page 2

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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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