Capital Nat'l Bank v. Commissioner
United States Tax Court
1. Petitioner issued time certificates of deposit which were outstanding in 1942 and 1943. Held: The certificates of deposit are not includible in petitioner's borrowed capital for 1942 and 1943. National Bank of Commerce, 16 T. C. 579, followed. 2. Petitioner, a national bank on the charge-off basis as to bad debts in 1930, 1931, and 1932 reduced its accumulated earnings and profits on the recommendation of the national bank examiner by $ 50,000 in both 1930 and 1931…
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1. Petitioner issued time certificates of deposit which were outstanding in 1942 and 1943. Held: The certificates of deposit are not includible in petitioner's borrowed capital for 1942 and 1943. National Bank of Commerce, 16 T. C. 579, followed. 2. Petitioner, a national bank on the charge-off basis as to bad debts in 1930, 1931, and 1932 reduced its accumulated earnings and profits on the recommendation of the national bank examiner by $ 50,000 in both 1930 and 1931 because of the partial worthlessness of Reclamation District bonds by setting up a reserve for depreciation in value. It did…
1Opinion of the Court
The Capital National Bank of Sacramento, Petitioner, v. Commissioner of Internal Revenue, Respondent
Capital Nat'l Bank v. Commissioner
Docket No. 20262
United States Tax Court
16 T.C. 1202; 1951 U.S. Tax Ct. LEXIS 180;
May 29, 1951, Promulgated
Decision will be entered under Rule 50.
1. Petitioner issued time certificates of deposit which were outstanding in 1942 and 1943. Held: The certificates of deposit are not includible in petitioner's borrowed capital for 1942 and 1943. National Bank of Commerce, 16 T. C. 579, followed.
2. Petitioner, a national bank on the charge-off basis as to bad debts in…
2Cases cited18 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Elliott v. Capital City State BankSupreme Court of Iowa · 1905
- Pancoast Hotel Co. v. CommissionerUnited States Tax Court · 1943
- Blair v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937
- Commissioner of Internal Revenue v. Ames Trust & Sav. BankCourt of Appeals for the Eighth Circuit · 1950
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