Industry Issue Resolution Pilot Program under
Notice 2000-65
Financial Services Issues
Contents | Introduction | I | II | III
Final Comment
We would be remiss if we did not include a comment on what we believe is the most
significant tax controversy currently facing the banking industry - the treatment of loan
origination costs. We view the recent decision in the case of PNC Bancorp, Inc. v.
Commissioner,8
as the correct interpretation of the law. Based on our conversations with IRS officials,
it appears that the Service may be close to issuing guidance on this issue, which we
presume would be consistent with the Third Circuit decision. If so, then the treatment of
loan origination may not be one that needs to be resolved under the industry issue
resolution pilot program. If our assessment is incorrect, however, and if the Service
decides to address loan origination costs under the pilot program, we would welcome that
action.
Contents | Introduction
| I | II | III |