- 5 - in 1981. During the years in issue, 1986 through 1988, Moore Financial was the parent corporation of IFNB.5 In 1986, IFNB was a "bank", as defined in section 581, that was entitled to and did use the cash method of accounting for Federal income tax purposes.6 Also during 1986, IFNB was the largest commercial and agricultural lender in Idaho. As a large commercial bank, IFNB made numerous loans of different maturities in the ordinary course of its business, including loans of less than 1 year, 1- year loans, and loans of more than 1 year. The short-term obligations in issue here all had periods to maturity of 1 year or less and consisted of the following: Principal Accrued Interest Description Balances as of 12/31/86 Time deposits with banks 1$164,000,000 1$970,214 CD's with banks 243,000,000 22,373,410 Consumer loans 16,626,503 381,325 Commercial and agricultural loans 3356,888,213 36,092,248 Total 4580,514,716 49,817,197 5 After the years at issue (in 1989) Moore Financial changed its name to West One Bancorp (West One). In 1995, West One merged into U.S. Bancorp (Old Bancorp). In 1997, Old Bancorp merged into First Bank System, Inc., a bank holding company, which changed its name to U.S. Bancorp (the petitioner in this case). 6 IFNB switched to the accrual method of accounting for 1987, as required by sec. 448, enacted by TRA 1986. See supra note 4.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011