United States Tax Court April 13, 2001, No. 19780-98 (Metrocorp, Inc. v. Commissioner)

CHIECHI, J.,

concurring: Respondent chose to ask the Court to decide the issue of whether the exit fee and the entrance fee should be capitalized solely on the basis of respondent’s theory that those fees generated certain significant future benefits for Metrobank. The majority states that it will “decide this case as framed by respondent”. Majority op. p. 217.