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LINCOLN SAVINGS & LOAN ASSOCIATION v. COMMISSIONER

Docket No. 325-67.

51 T.C. 82 (1968)

LINCOLN SAVINGS & LOAN ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 21, 1968.

Attorney(s) appearing for the Case

Adam Y. Bennion, A. Calder Mackay, and Richard N. Mackay, for the petitioner.

James A. Thomas, for the respondent.

The Commissioner determined a deficiency in petitioner's income tax of $461,454.38 for the year 1963. Petitioner disputes so much of that deficiency as is based upon the Commissioner's disallowance of a deduction in the amount of $882,636.86, which petitioner claimed as a "Federal Insurance Premium" expense in that year. Petitioner paid this amount to the Federal Savings and Loan Insurance Corporation in 1963, as well as its regular annual insurance premium for that year...

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