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SECURITY STATE BANK v. C.I.R.

No. 99-9002.

214 F.3d 1254 (2000)

SECURITY STATE BANK, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Tenth Circuit.

June 7, 2000.

Attorney(s) appearing for the Case

Martin J. Peck, Wellington, Kansas, for Petitioner-Appellee.

Charles Bricken (Loretta C. Argrett, Assistant Attorney General, and Jonathan S. Cohen with him on the briefs), Department of Justice, Washington, D.C., for Respondent-Appellant.

Before SEYMOUR, BRORBY and EBEL, Circuit Judges.

BRORBY, Circuit Judge.

In this appeal, we are faced with precisely the issue decided by the Eighth Circuit in Security Bank Minnesota v. Commissioner, 994 F.2d 432 (8th Cir. 1993):

whether § 1281 of the Internal Revenue Code, which requires certain taxpayers to accrue discount and interest income on certain short-term obligations, requires a commercial bank, otherwise reporting its income on the cash basis, to...

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