Central Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Under an agreement between petitioner and another national bank, petitioner sold all its assets to the other bank and agreed to liquidate, and in consideration the other bank assumed all liabilities of petitioner to its depositors and creditors and also agreed to pay petitioner a certain sum which represented the total amount of petitioner's capital, surplus and undivided profits, plus an agreed amount for good will.
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1. Under an agreement between petitioner and another national bank, petitioner sold all its assets to the other bank and agreed to liquidate, and in consideration the other bank assumed all liabilities of petitioner to its depositors and creditors and also agreed to pay petitioner a certain sum which represented the total amount of petitioner's capital, surplus and undivided profits, plus an agreed amount for good will. Held, the transaction was not a reorganization under section 112, Revenue Act of 1928, but a sale. Pinellas Ice & Cold Storage Co. v. Commissioner,287 U.S. 462, followed. 2.…
1Opinion of the Court
CENTRAL NATIONAL BANK OF LINCOLN, NEBRASKA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Central Nat'l Bank v. Commissioner
Docket No. 59285.
United States Board of Tax Appeals
29 B.T.A. 719; 1934 BTA LEXIS 1493;
January 10, 1934, Promulgated
1. Under an agreement between petitioner and another national bank, petitioner sold all its assets to the other bank and agreed to liquidate, and in consideration the other bank assumed all liabilities of petitioner to its depositors and creditors and also agreed to pay petitioner a certain sum which represented the total amount of petitioner's…
2Cases cited2 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Central Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1934