- 13 - Respondent has not brought to our attention any "prudential and pragmatic considerations", see Planned Parenthood v. Casey, 505 U.S. 833, 854 (1992), that would lead us to conclude that the principle of stare decisis should not hold sway.11 See also Helvering v. Hallock, 309 U.S. 106, 119 (1940). As we stated in Security State Bank v. Commissioner, 111 T.C. at 213-214: Security Bank Minn. v. Commissioner [citation omitted] was a Court-reviewed opinion. The majority opinion contains an extensive analysis of the statute, its evolution, the context in which it appears, and its legislative history. There was a dissenting opinion which was joined by five Judges. In affirming our 10(...continued) agricultural loans at issue in Security Bank. Minn. v. Commissioner, 98 T.C. 33 (1992), affd. 994 F.2d 432 (8th Cir. 1993) (and in Security State Bank v. Commissioner, 111 T.C. 210 (1998)), provided for payments of interest as well as principal only at maturity. Even though respondent’s arguments in Security Bank Minn. arguably are more directly applicable to the loans to customers in the case at hand than they were to the loans in Security Bank Minn. and Security State Bank--after all, the reference to “any interest payable on the obligation” would seem to apply directly to the interest payable monthly and quarterly in the case at hand, as opposed to the interest payable at maturity in Security Bank Minn. and Security State Bank, which seems more like OID--this does not change our conclusion that all respondent has done in mounting his primary argument is to ask us to overrule Security Bank Minn., as stated in the text. 11 Indeed, those considerations point in the other direction. The issues in this case have limited significance in subsequent years because of the enactment of sec. 448, requiring C corporations, including large banks such as IFNB, with average annual gross receipts of more than $5 million, to switch to the accrual method of accounting, effective for 1987 and subsequent years. Petitioner observes that our ruling in this matter will not apply to petitioner for any other tax year and is not likely to apply to any other large commercial bank.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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