- 9 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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