Federal Home Loan Mortgage Corporation - Page 15

                                       - 15 -                                         
          funds on deposit for predictable periods of time.’”  Id. at 562             
          (quoting Citizens & S. Corp. v. Commissioner, supra at 500); see            
          also Colo. Natl. Bankshares, Inc. v. Commissioner, T.C. Memo.               
          1990-495, affd. 984 F.2d 383 (10th Cir. 1993).                              
               Core deposits typically consist of low-cost accounts such as           
          regular savings accounts, deposit transaction accounts (e.g.,               
          regular checking accounts), time deposit open accounts, etc., see           
          Citizens & S. Corp. v. Commissioner, supra at 465, but do not               
          typically include “Adjustable rate deposit accounts”, such as               
          certificates of deposit, money market deposit accounts, and super           
          NOW (negotiable order of withdrawal) accounts, which are designed           
          to be sensitive to market interest rates, see IT&S of Iowa, Inc.            
          v. Commissioner, 97 T.C. 496, 517 (1991); Peoples Bancorporation            
          & Subs. v. Commissioner, T.C. Memo. 1992-285.  In Citizens & S.             
          Corp. v. Commissioner, supra at 465-466, we described core                  
          deposits as:                                                                
               a relatively low-cost source of funds, reasonably                      
               stable over time, and relatively insensitive to                        
               interest rate charges.  A bank typically invests the                   
               funds from deposits in loans and other income-producing                
               assets, and receives fees for services rendered to its                 
               depositors.  A bank also incurs expenses in                            
               establishing, processing, and maintaining deposit                      
               accounts.  The excess of the income generated over the                 
               associated costs represents the profit attributable to                 
               core deposits. * * *                                                   
               In Citizens & S. Corp., the seminal case involving deposit             
          base, the taxpayer sought to amortize the deposit base that it              







Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next

Last modified: May 25, 2011