Garrison Bros. State Bank v. Commissioner

WILBUR, Circuit Judge.

The petitioner disposed of its business and good will to a new bank, called the Bank of Sumas, organized for that purpose. The appellee determined that it made a profit of $8,-614 on the transfer, which amount was taxable income, being net profits from the sale of its banking business. The commissioner claimed that for the consideration of $40,000 paid by the newly organized bank, $10,000 of which was paid to Loomis and Brygger, the petitioner transferred assets of the net worth of $31,386, leaving a profit of $8,614. Petitioner’s building was transferred at a value of…