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CHESAPEAKE FINANCIAL CORP. v. COMMISSIONER

Docket No. 10623-78.

78 T.C. 869 (1982)

CHESAPEAKE FINANCIAL CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 27, 1982.

Attorney(s) appearing for the Case

Richard W. Case and David Bielawski, for the petitioner.

R. Dale Eggleston, for the respondent.

WILBUR, Judge:

Respondent determined deficiencies in petitioner's 1973, 1974, and 1975 Federal income taxes in the respective amounts of $438,892.76, $145,186.67, and $70,163.54. Concessions having been made, the sole issue for decision is whether petitioner was entitled to defer the recognition of permanent loan commitment fees until the related permanent loans were funded.

FINDINGS OF FACT

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