Legal Opinion

Security Cent. Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided October 31, 1935No. Docket No. 73554Published

In the "merger" of a state bank under the charter of petitioner, a national bank, each bank contributed an agreed amount of the increased capital, surplus, and undivided profits of petitioner, and transferred its remaining assets to trustees, in trust, under terms whereby for a period of two years the petitioner could substitute bad assets for good assets placed in trust by the contributing bank.

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In the "merger" of a state bank under the charter of petitioner, a national bank, each bank contributed an agreed amount of the increased capital, surplus, and undivided profits of petitioner, and transferred its remaining assets to trustees, in trust, under terms whereby for a period of two years the petitioner could substitute bad assets for good assets placed in trust by the contributing bank. The new stock of petitioner was distributed among the stockholders of the respective banks according to the contributions made, and the trustees issued certificates to the old stockholders to…

1Opinion of the Court

THE SECURITY CENTRAL NATIONAL BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Security Cent. Nat'l Bank v. Commissioner

Docket No. 73554.

United States Board of Tax Appeals

33 B.T.A. 349; 1935 BTA LEXIS 761;

October 31, 1935, Promulgated

In the "merger" of a state bank under the charter of petitioner, a national bank, each bank contributed an agreed amount of the increased capital, surplus, and undivided profits of petitioner, and transferred its remaining assets to trustees, in trust, under terms whereby for a period of two years the petitioner could substitute bad assets for…

2Cases cited1 opinion

  1. Security Cent. Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1935

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