- 3 - 1987 gross income.4 Respondent's cross-motion asks for an order denying petitioner's motion in full and granting partial summary judgment for respondent. Subsequent to the submissions of the parties, we followed and applied Security Bank Minn. v. Commissioner, supra, in Security State Bank v. Commissioner, 111 T.C. 210 (1998). With respect to IFNB's consumer, commercial, and agricultural short-term loans made to its customers, we follow our decisions in Security Bank Minn. v. Commissioner, supra, and Security State Bank v. Commissioner, supra, hold for petitioner, grant petitioner's motion, and deny respondent's motion. By reason of petitioner's concession, the interest that accrued on such loans in 1986 is included in petitioner's income in full in 1987. With respect to the certificates of deposit (CD's) and time deposits owned by IFNB in 1986, we deny petitioner's motion and respondent's cross-motion. Respondent's arguments with respect to the CD's and time deposits raise questions of fact regarding banking and commercial practices. These questions must be 4 Petitioner has conceded that it is not entitled to its reporting position that the interest in issue that was received in 1987 should be spread ratably over the 4 years 1987-90 as a sec. 481 change in accounting method adjustment under sec. 448(d)(7), as enacted by the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 801(a), 100 Stat. 2347 (TRA 1986). Sec. 448 requires C corporations having average annual gross receipts of more than $5 million to switch to the accrual method of accounting for 1987 and later years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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