Signet Banking Corp. v. Comm'r of Internal Revenue

1 Citing case

  1. PSB Holdings, Inc. v. Comm'r of Internal Revenue

    129 T.C. 131 (U.S.T.C. 2007)   Cited 12 times

    Neither financial nor regulatory accounting controls the manner in which a taxpayer must report its operations for Federal income tax purposes. See Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 542–543, 99 S.Ct. 773, 58 L.Ed.2d 785 (1979); Signet Banking Corp. v. Commissioner, 106 T.C. 117, 130–131, 1996 WL 85845 (1996), affd. 118 F.3d 239 (4th Cir.1997). In fact, we note another major difference from the manner in which Investments is treated for Federal income tax purposes; to wit, that Investments is considered to be a financial institution for Federal and State oversight purposes but is not considered to be a bank or financial institution for Federal income tax purposes.