opinion: WILSON BANKING COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
  Circuit Court of Appeals, Fifth Circuit.
  February 25, 1929.
  Rehearing Denied March 25, 1929.
  No. 5385.
  St. Clair Adams, of New Orleans, La. (G. A. Wilson, of; Greenwood, Miss., on the brief), for petitioner.
  Mabel Walker Willebrandt, Asst. Atty. Gen., Sewall Key and Harvey R. Gamble, Sp. Assts. to the Atty. Gen., and C. M. Charest, General Counsel, Bureau of Internal Revenue, and Thos. P. Dudley, Jr., Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C. (Irwin R. Blaisdell, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C., on the brief), for respondent.
  Before WALKER, BRYAN, and FOSTER, Circuit Judges.
  FOSTER, Circuit Judge.
  In this case the material facts axe these: Petitioner is a Mississippi hanking corporation, with a capital stock of $25,000, all of which, except qualifying shares, is owned by G. A. Wilson. When the bank was organized, G. A. Wilson deposited eight promissory notes, of the face value of $174,100. The notes were paid at maturity. The interest, amounting to some $12,000, was credited to the surplus of the honk and the balance was credited to Wilson’s account. There were very few withdrawals from this account, and from time to time it was increased. However, it was always subject to be checked out by Wilson. Petitioner, in making his returns for profit taxes for 1919 and 1920, sought to include this account as capital. This was rejected by the Commissioner of Internal Revenue, and the tax determined accordingly. On appeal to the Board of Tax Appeals, the ruling of the Commissioner was sustained. The ease presents merely questions of fact, and we find nothing in the record that would warrant a reversal of the judgment.
  Affirmed.
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "financial institution". Your task is to determine what subcategory of business best describes this litigant.
choices: bank insurance savings and loan credit union other pension fund other financial institution or investment company unclear