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PSB HOLDINGS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
- Article from:
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United States. Tax Court. Reports
- Article date:
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November 1, 2007
- Author:
- Anonymous
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Copyright informationCopyright Superintendent of Documents Nov 1-Dec 31, 2007. Provided by ProQuest LLC. (Hide copyright information)
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Docket No. 14724-05. Filed November 1, 2007.
P is the holding company of an affiliated group of corporations that files consolidated Federal income tax returns. The other members are Fs wholly owned bank (B) and B's wholly owned investment company (IC). Both B and IC own taxexempt obligations. Only B incurs interest expenses. ICs taxexempt obligations were either purchased by IC or received from B before the subject years as contributions to capital. R determined that B must include all of ICs tax-exempt obligations in the calculation of B's average adjusted bases of taxexempt obligations under sees. 265(b)(2)(A) and 29Ke)(I)(B)(U)(I), I.R.C. On the consolidated income tax returns for the ...