Commissioner v. Lincoln Savings & Loan Assn. - 403 U.S. 345 (1971)

U.S. Supreme Court

Commissioner v. Lincoln Savings & Loan Assn., 403 U.S. 345 (1971)

Commissioner of Internal Revenue v.

Lincoln Savings & Loan Assn.

No. 544

Argued February 23, 1971

Decided June 14, 1971

403 U.S. 345

Syllabus

Payment by a state-chartered savings and loan association of the "additional premium" required by § 404(d) of the National Housing Act to be paid to the Federal Savings and Loan Insurance Corp. is not deductible for income tax purposes as an ordinary and necessary business expense under § 162(a) of the Internal Revenue Code. Pp. 403 U. S. 352-359

422 F.2d 90, reversed.

BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and BLACK, HARLAN, BRENNAN, STEWART, WHITE, and MARSHALL, JJ., joined. DOUGLAS, J., filed a dissenting opinion, post, p. 403 U. S. 359.