U.S. Bancorp, Successor In Interest to West One Bancorp and Subsidiaries, formerly known as Moore Financial Group, Inc. - Page 19

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          respondent's proposed application of section 1281(a)(1) presented           
          an issue of first impression in Security State Bank v.                      
          Commissioner, 111 T.C. at 214.  However, after examining our                
          approach in Security Bank Minn., we concluded in Security State             
          Bank v. Commissioner, supra, that:                                          
                    Our analysis in Security Bank Minn. v.                            
               Commissioner, supra, makes clear that we have                          
               interpreted section 1281 as having no application                      
               to loans made by banks in the ordinary course of                       
               business, regardless of whether the loans are                          
               characterized as generating interest or original issue                 
               discount.  We, therefore, hold that section 1281(a)(1)                 
               does not apply to the loans in issue.  [Id. at 215; fn.                
               ref. omitted.]                                                         
               In the case at hand, we follow Security Bank Minn. v.                  
          Commissioner, supra, as explained by Security State Bank v.                 
          Commissioner, supra, to hold that no accrual is required under              
          section 1281(a)(1) with respect to IFNB's consumer, commercial,             
          and agricultural short-term loans to its customers.                         
          V.   Respondent's Third Argument:  IFNB's Time Deposits and                 
               CD's Are Not "Bank Loans Made to Customers"                            
               As an alternative to the foregoing arguments, which relate             
          to all the short-term obligations held by IFNB during the years             
          at issue, respondent makes a third argument, which applies only             
          to IFNB's time deposits and CD's, the obligors of which were                
          other banks.                                                                
               In essence, respondent asserts that even if Security Bank              
          Minn. v. Commissioner, supra, and Security State Bank v.                    
          Commissioner, supra, were properly decided, the legal standard we           




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