Legal Opinion
New Jersey Title Guarantee & Trust Co. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 19, 1950No. 21629_1PublishedCited by 2 opinions
1Opinion of the Court
CLARK, Circuit Judge.
Petitioner seeks review of a decision of the Tax Court, 13 T.C. 674, one judge dissenting, holding that the exemption from payment of taxes granted insolvent state banks by I.R.C. § 3798, 26 U.S.C.A. § 3798, does not apply to such a bank’s statutory liability to pay a tax as transferee of assets of one from whom the tax is due.
The Bank of Lafayette was merged in 1931 with petitioner, whose property and assets were taken over for liquidation by the Commissioner of Banking and Insurance of the State of New Jersey on February 14, 1939. The present question has arisen in…
2Cases cited12 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- United States v. UpdikeSupreme Court of the United States · 1930
- COMMISSIONER OF INT. REVENUE v. Oswego Falls Corp.Court of Appeals for the Second Circuit · 1934
- Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
- Cappellini v. CommissionerUnited States Board of Tax Appeals · 1929
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3Cited by2 opinions
- De Kalb Trust & Savings Bank v. United StatesCourt of Appeals for the Seventh Circuit · 1958
- Bank of Leipsic Company v. United StatesCourt of Appeals for the Sixth Circuit · 1961