James E. Blasius and Mary Jo Blasius, et al. - Page 9

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          analyzing credit applications submitted by the dealers’                     
          customers, analyzing credit reports, verifying information                  
          provided by credit applicants (the credit analysis activities),             
          and purchasing the approved installment contracts from the                  
          dealers.  Those costs consisted of employee salaries and benefits           
          deemed attributable to the foregoing activities.                            
               Professional Fees                                                      
               The professional fees at issue in the consolidated cases               
          (professional fees) were payments, apparently to third parties,             
          relating to the creation of a bank line of credit for ACC, which            
          extended over 2 calendar years.                                             
          Chronology of Administrative and Judicial Developments                      
          Regarding the Capitalization Versus Expense Issues Conceded by              
          Respondent in the Consolidated Cases                                        
               Cases and Public Pronouncements                                        
               On June 8, 1998, this Court issued its report in PNC                   
          Bancorp, Inc. v. Commissioner, 110 T.C. 349 (1998), revd. 212               
          F.3d 822 (3d Cir. 2000), in which we held that a bank’s costs               
          associated with making loans extending beyond the years in which            
          the costs were incurred, including salaries and benefits paid to            
          employees, are not currently deductible under section 162(a) and            
          must be capitalized under section 263(a).                                   
               On March 8, 1999, this Court issued its report in Norwest              
          Corp. v. Commissioner, 112 T.C. 89 (1999), affd. in part and                
          revd. in part sub nom. Wells Fargo & Co. & Subs. v. Commissioner,           






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