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PNC BANCORP, INC. v. C.I.R.

No. 99-6020.

212 F.3d 822 (2000)

PNC BANCORP, INC., Successor to First National Pennsylvania Corporation v. COMMISSIONER OF INTERNAL REVENUE (Tax Court No. 95-16002) PNC BANCORP, INC., Transferee of Assets of First National Pennsylvania Corporation v. COMMISSIONER OF INTERNAL REVENUE (Tax Court No. 95-16003) PNC Bancorp, Inc., Successor to United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16109) PNC Bancorp, Inc., Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16110) PNC Bancorp, Inc., as (i) Successor to First National Pennsylvania Corporation, (ii) Transferee of Assets of First National Pennsylvania Corporation, (iii) Successor to United Federal Bancorp, Inc., and Subsidiaries, and (iv) Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries, Appellant.

United States Court of Appeals, Third Circuit.

Filed May 19, 2000.

Attorney(s) appearing for the Case

Robert J. Jones, Esq. (Argued), Roger P. Colinvaux, Esq., Arnold & Porter, Washington, DC, Attorneys for Appellant.

Richard Farber, Esq., Annette M. Wietecha, Esq. (Argued), U.S. Department of Justice, Tax Division, Washington, DC, Attorneys for Appellee.

Michael F. Crotty, Esq., American Bankers Association, Washington, DC, Attorney for Amicus-Appellant American Bankers Association.

Maureen E. Mahoney, Esq., Latham & Watkins, Washington, DC, Attorney for Amicus-Appellant National Association of Manufacturers.

Ronald W. Blasi, Esq., Georgia State University College of Law, Atlanta, GA, Attorney for Amicus-Appellant Ronald W. Blasi.

Before: SLOVITER, RENDELL, Circuit Judges, and BYRNE, District Judge.

OPINION OF THE COURT

RENDELL, Circuit Judge.

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. § 162 (1988), or whether these expenses must be capitalized under section 263 of the Code. Two banks that were predecessors in...

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