§591 — Deduction for dividends paid on deposits

14 cases·3 followed·2 distinguished·9 cited—21% support

Statute Text — 26 U.S.C. §591

(a)In general

In the case of mutual savings banks, cooperative banks, domestic building and loan associations, and other savings institutions chartered and supervised as savings and loan or similar associations under Federal or State law, there shall be allowed as deductions in computing taxable income amounts paid to, or credited to the accounts of, depositors or holders of accounts as dividends or interest on their deposits or withdrawable accounts, if such amounts paid or credited are withdrawable on demand subject only to customary notice of intention to withdraw.

(b)Mutual savings bank to include certain banks with capital stock

For purposes of this part, the term “mutual savings bank” includes any bank—

(1)

which has capital stock represented by shares, and

(2)

which is subject to, and operates under, Federal or State laws relating to mutual savings bank.

Treasury Regulations

Treas. Reg. §Treas. Reg. §1.591-1 Deduction for dividends paid on deposits
Treas. Reg. §Treas. Reg. §1.591-1(a) In general.
Treas. Reg. §Treas. Reg. §1.591-1(b) Serial associations, bonus plans, etc.
Treas. Reg. §Treas. Reg. §1.591-1(c) Effective date.

14 Citing Cases

Barnett Banks, Inc. & Subsidiaries, Petitioner T.C. Memo. 2002-168 · 2002

imary source of residential home mortgages. Alternatively, petitioner argues that Southwest and Pinellas qualify as “mutual savings banks” as defined in section 591(b). Section 591(b) expands the definition of a “mutual savings bank” for purposes of section 591. Section 591 provides: SEC. 591. DEDUCTION FOR DIVIDENDS PAID ON DEPOSITS. (a) In General.-–In the case of mutual savings banks, cooperative banks, domestic building and loan associations, and other savings institutions chartered and supe

Joseph D. Specking, Petitioner 117 T.C. No. 9 · 2001

591.402 (2001); 19 C.F.R. sec. 7.2 (2000); 50 C.F.R. sec. 32.7 (2000); 14 Op. Atty. Gen. 608 (1873); 9 Op. Atty. Gen. 364 (1859); The U.S. Constitution and Insular Areas, supra at 39-40, 50-51; U.S. 5We rely on judicial notice and stipulations of the parties for statements describing Johnston Island and Johnston Atoll. 6Johnston Atoll, further

Eric N. Umbach, Petitioner 117 T.C. No. 9 · 2001

Joyce Aston, Petitioner 109 T.C. No. 18 · 1997

* * * * * * * (3) Qualified financial institution.-- For purposes of this subsection, the term "qualified financial institution" means-- - 17 - (A) any bank (as defined in section 581), (B) any institution described in section 591, (C) any credit union the deposits or accounts in which are insured under Federal or State law or are protected or guaranteed under State law, or (D) any similar institution chartered and supervised under Federal or State law.

Aston v. Commissioner 109 T.C. 400 · 1997

— For purposes of this subsection, the term “qualified financial institution” means— (A) any bank (as defined in section 581), (B) any institution described in section 591, (C) any credit union the deposits or accounts in which are insured under Federal or State law or are protected or guaranteed under State law, or (D) any similar institution chartered and supervised under Federal or State law.

Midwest Savings Ass'n v. Commissioner 75 T.C. 262 · 1980

Hudson City Savings Bank v. Commissioner 53 T.C. 70 · 1969

Southern California Savings & Loan Ass'n v. Commissioner 95 T.C. 35 · 1990

Colonial Savings Ass'n & Subsidiaries v. Commissioner 85 T.C. 855 · 1985

Sang J. Park v. Commissioner 136 T.C. 569 · 2011

Estate of Schwartz v. Commissioner 83 T.C. 943 · 1984

Lilly v. Commissioner 45 T.C. 168 · 1965

Neill v. Commissioner 17 T.C. 1015 · 1951

Rodriguez v. United States 852 F.3d 67 · Cir.