PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 3

                                          3                                           

               The sole issue for decision is whether loan origination                
          expenditures were ordinary and necessary business expenses                  
          properly deductible under section 162(a)3 or whether they are               
          required to be capitalized under section 263.                               

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are incorporated            
          herein by this reference.                                                   
               During the years in issue, First National Pennsylvania Corp.           
          (FNPC) was a corporation organized under the laws of Pennsylvania           
          and was the owner of all the stock of the First National Bank of            
          Pennsylvania (FNBP), East Bay Mortgage Co., and other                       
          corporations which joined with FNPC in the filing of consolidated           
          Federal corporation income tax returns (Forms 1120) (the FNPC               
          Group).  The Forms 1120 of the FNPC Group for the calendar years            
          1988, 1989, and 1990 were prepared using the accrual method of              
          accounting.                                                                 
               During the years 1990 through 1993, United Federal Bancorp,            
          Inc. (UFB) was a corporation organized under the laws of                    
          Pennsylvania and was the owner of all the stock of the United               
          Federal Savings Bank (UFSB) and other corporations which joined             
          with UFB in the filing of Forms 1120 (the UFB Group).  The Forms            



               3Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules on                
          Practice and Procedure.                                                     


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