Ellis Banking Corp. v. Commissioner
United States Tax Court
Held, certain accounting and other expenses incurred by petitioner, a bank holding corporation, were incurred in connection with the acquisition of the stock of another bank, a capital asset, and must be capitalized and are not deductible as ordinary and necessary business expenses.
1Opinion of the Court
ELLIS BANKING CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ellis Banking Corp. v. Commissioner
Docket No. 13848-78.
United States Tax Court
T.C. Memo 1981-123; 1981 Tax Ct. Memo LEXIS 622; 41 T.C.M. (CCH) 1107; T.C.M. (RIA) 81123;
March 17, 1981.
Held, certain accounting and other expenses incurred by petitioner, a bank holding corporation, were incurred in connection with the acquisition of the stock of another bank, a capital asset, and must be capitalized and are not deductible as ordinary and necessary business expenses.
Michel G. Emmanuel and Nathaniel L. Doliner, for…
2Cases cited20 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Commissioner v. TellierSupreme Court of the United States · 1966
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Helvering v. WinmillSupreme Court of the United States · 1938
15 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Ellis Banking Corporation v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1982