- 9 - 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.4 We, therefore, hold that section 1281(a)(1) does not apply to the loans in issue. Decision will be entered for petitioner. 4Because of our legal conclusion, there is no need to decide whether respondent is correct in characterizing the loans in issue as generating original issue discount.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011