- 12 - We consider respondent's arguments seriatim. In so doing, we explain why summary judgment is appropriate with respect to IFNB's consumer, commercial, and agricultural loans but is not appropriate with respect to its time deposits and CD's. III. Respondent's First Argument: Security Bank Minn. v. Commissioner Should Be Overruled Respondent first asks the Court to reconsider its holding in Security Bank Minn. v. Commissioner, supra, that section 1281(a)(2) of the short-term obligation rules does not require a 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. In short, respondent here argues, as in Security Bank Minn., that section 1281(a)(2) requires the accrual of interest on all short-term obligations held by a bank--without regard to the type of obligations involved, or the manner in which the bank came to hold them. Although respondent advances this argument with force and cogency--and also tries to identify certain factual differences between the loans at issue in this case and the loans considered in Security Bank Minn. v. Commissioner, supra--we believe that all respondent has done in advancing this argument is to ask us to overrule Security Bank Minn., which we decline to do.10 10 For example, we note that most of IFNB's consumer, commercial, and agricultural loans provided for payments of interest at monthly intervals, as well as at maturity, while the (continued...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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