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SECURITY BANK MINNESOTA v. COMMISSIONER

Docket No. 7552-90.

98 T.C. 33 (1992)

SECURITY BANK MINNESOTA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 21, 1992.

Attorney(s) appearing for the Case

Sue Ann Nelson and Terrance A. Costello, for petitioner.

John C. Schmittdiel, for respondent.

OPINION

COHEN, Judge:

Respondent determined a deficiency of $48,437.80 in petitioner's Federal income tax for 1986. The issue for decision is whether section 1281 requires petitioner, a commercial bank, to accrue interest on short-term loans made to customers in the ordinary course of its business. If section 1281 does apply to the loans in question, we must determine whether certain of the loans made to petitioner's customers were or were not short...

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