PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 17

                                         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 these                 



Page:  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