[DOWNLOAD] "Pnc Bancorp" by Third Circuit U.S. Court Of Appeals # Book PDF Kindle ePub Free
eBook details
- Title: Pnc Bancorp
- Author : Third Circuit U.S. Court Of Appeals
- Release Date : January 19, 2000
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 77 KB
Description
In this appeal from a decision of the Tax Court, we are asked to determine whether certain costs incurred by banks for marketing, researching and originating loans are deductible as "ordinary and necessary expenses" as provided by section 162 of the Internal Revenue Code, 26 U.S.C. S 162 (1988), or whether these expenses must be capitalized under section 263 of the Code. Two banks that were predecessors in interest of appellant PNC Bancorp, Inc. deducted these costs as ordinary business expenses. The Internal Revenue Service disallowed the deductions and issued statutory notices of deficiency. PNC filed petitions for redetermination with the Tax Court. The Tax Court determined that the expenses in question were not deductible, but, instead, must be capitalized and amortized over the life of the subject loans. PNC now appeals from this determination.