COLONIAL SAV. ASS'N AND SUBSIDIARIES v. C.I.R.

Nos. 87-1012, 87-1633, 87-1499 & 87-1500.

854 F.2d 1001 (1988)

COLONIAL SAVINGS ASSOCIATION AND SUBSIDIARIES, Petitioners-Appellants, Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Cross-Appellant. FRONTIER SAVINGS AND LOAN ASSOCIATION, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided August 10, 1988.

Rehearing and Rehearing Denied September 13, 1988.


Attorney(s) appearing for the Case

Robert A. Schnur, Best & Friedrich, Milwaukee, Wis., for petitioners-appellants, cross-appellees.

Roger M. Olsen, Asst. Atty. Gen., Appellate Sec., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee, cross-appellant.

Before BAUER, Chief Judge, RIPPLE, Circuit Judge, and WILL, Senior District Judge.


Rehearing and Rehearing En Banc Denied in Nos. 87-1012 and 87-1663 September 13, 1988.

RIPPLE, Circuit Judge.

These appeals present two separate questions of tax law, and require us to review two different decisions of the United States Tax Court.1 The first issue is whether early withdrawal penalties received by banking institutions from depositors constitute discharge of indebtedness income to the institutions under section 108...

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