17 The evidence does not separately identify the allocated costs that were reflected in the FNPC ledger accounts used by respondent in calculating the disallowed amounts. However, because those ledger accounts were established in order to comply with SFAS 91, the allocated costs reflected in the disallowed amounts necessarily consisted of some combination of the following: (1) Costs paid by FNBP to third parties for property reports, credit reports and appraisals, and costs for recording security interests, and (2) an allocable portion of the costs incurred by FNBP for salaries and benefits of its employees (and related costs) attributable to the following activities: Evaluating the financial condition of prospective borrowers; evaluating and recording guaranties, collateral and other security arrangements; negotiating loan terms; preparing and processing loan documents; and closing loan transactions. The costs at issue in the FNPC cases do not include any costs incurred in connection with unsuccessful loan efforts (i.e., where a loan was not originated) or any costs incurred following a loan's origination by FNBP. Respondent disallowed FNPC's claimed deductions for loan origination costs in the amounts of $568,283, $392,321, and $26,060 in taxable years 1988, 1989, and 1990, respectively. These adjustments represent amounts (net of amortization or yield adjustments) that were deferred by FNPC in its ledger accounts to comply with SFAS 91 for financial accounting and reporting purposes. The fees and costs included in determining thesePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011