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to short-term loans made by banks in the ordinary course of
business. Respondent recognizes that our prior opinion precludes
application of section 1281(a)(2) to the facts in the instant
case, unless we choose to overrule it. Respondent urges us to do
just that.
Security Bank Minn. v. Commissioner, supra, 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
opinion, the Court of Appeals for the Eighth Circuit also made an
extensive analysis of the same factors. One of the judges on the
Court of Appeals panel dissented.
No purpose would be served by repeating the statutory
analysis that led this Court and the Court of Appeals to decide
that section 1281(a)(2) does not apply to loans made by banks in
the ordinary course of business. Suffice it to say that this
matter has been thoroughly considered and decided. The doctrine
of stare decisis generally requires that we follow the holding of
a previously decided case, absent special justification. This
doctrine is of particular importance when the antecedent case
involves statutory construction. Hesselink v. Commissioner, 97
T.C. 94, 99-100 (1991). While respondent has skillfully
rearticulated his arguments in support of a different
interpretation of the statute, we find nothing therein that would
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