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