In Bank of America v. United States, 680 F.2d 142 (Ct.Cl.1982), the issue was whether certain commissions received by a taxpayer bank were U.S. source income or foreign source income for Internal Revenue Code Section 901 purposes. The bank received the commissions partly in return for its confirmation of letters of credit issued by foreign banks. In order to resolve the question of whether the commissions were foreignor U.S.-sourced, the court analogized the commissions to the two classes of income listed in Sections 861 and 862, interest income and personal income. The court declined to categorize the commissions as income derived from the performance of personal services, reasoning that the bank, in substituting its credit for that of other banks, engaged in what resembled a loan transaction rather than the performance of services. The court wrote: Thus, from the moment of confirmation the plaintiff has made an enforceable promise to pay regardless of any change in the foreign bank's financial condition. As in acceptance and loan transactions, the plaintiff here has acted as an intermediate, has assumed the risk of default of the foreign bank, and has assured the draft's holder of payment. Thus, it is apparent what plaintiff was really charging for was not the services performed but the substitution of its own credit for that of the foreign bank. The predominant feature of the confirmation transactions was the substitution of plaintiff's credit for that of the foreign banks. The services performed were subsidiary to this. Therefore, due to the similarities between a confirmation and a loan transaction, we hold that the confirmation commissions should be sourced by analogy to interest. 680 F.2d at 149-150.