Legal Opinion
AmSouth Bancorporation and Subsidiaries v. United States
District Court, N.D. Alabama
Decided February 25, 1988No. Civ. A. CV86-PT-1690-SPublishedCited by 11 opinions
1Opinion of the Court
FINDINGS OF FACT AND CONCLUSIONS OF LAW
PROPST, District Judge.
This cause came on to be heard at a bench trial which concluded on October 22, 1987.
THE ISSUE
Can a bank which acquires the assets and assumes the liabilities of another going concern bank assign some or all of the price paid in excess of tangible values purchased, to an intangible asset known as “customer deposit base” and capitalize, amortize and deduct the same pursuant to Section 167(a) of the Internal Revenue Code and Treasury Regulation § 1.167(a)?
FINDINGS OF FACT 1
The Players
AmSouth Bancorporation and Subsidiaries…
2Cases cited42 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
37 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- IT&S of Iowa, Inc. v. CommissionerUnited States Tax Court · 1991
- Citizens & Southern Corp. v. CommissionerUnited States Tax Court · 1988
- Southern Bancorporation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1988
- Newark Morning Ledger Co., as Successor to the Herald Company v. The United States of AmericaCourt of Appeals for the Third Circuit · 1991
- Newark Morning Ledger Co. v. United StatesDistrict Court, D. New Jersey · 1990
6 more not listed; retrieve them via the Exa API.