- 10 - and 1283(c), the holder of the obligation is required to include any "original issue discount" (OID) that accrues while it holds the obligation during the taxable year, in its interest income for that year. Second, under section 1281(a)(2), the holder is required to include any interest payable on that obligation in income as it accrues. In Security Bank Minn. v. Commissioner, supra, we considered the application of the short-term obligation rules to certain loans made by a bank. After a thorough consideration of the statutory language, the relevant legislative history, and the arguments of the parties, we concluded that the short-term obligation rules did not require the petitioning bank "to accrue interest on the short-term loans made to customers in the ordinary course of its business." Security Bank Minn. v. Commissioner, 98 T.C. at 43. Petitioner asserts that the short-term obligations at issue in this case are indistinguishable from the obligations we considered in Security Bank Minn. v. Commissioner, supra. As a result, argues petitioner, under the principle of stare decisis, we must hold that the short-term obligation rules do not require 9(...continued) (A) sections 1281 and 1282 shall be applied by taking into account original issue discount in lieu of acquisition discount * * *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