National Bank of Commerce v. Commissioner
United States Board of Tax Appeals
1. STATUTE OF LIMITATIONS. - Held that the respondent has failed to establish the validity of a waiver executed by a former officer of the National Bank of Commerce more than five years after the filing of the return.
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1. STATUTE OF LIMITATIONS. - Held that the respondent has failed to establish the validity of a waiver executed by a former officer of the National Bank of Commerce more than five years after the filing of the return. Assessment against that bank held to be barred. 2. Id. - TRANSFEREE. - Notice of deficiency having been mailed to the City National Bank as transferee of the National Bank of Commerce within one year after the statute had run against the transferor, held that the notice was timely and assessment is not barred. City National Bankheld to be a transferee of the National Bank of…
1Opinion of the Court
*1085OPINION.
Arundell:
The first error assigned is that the assessment of the deficiency in question is barred by the statute of limitations for the reason that the consents executed in 1926 are invalid in that C. E. Basham was without authority to sign these instruments. On April 30, 1920, the National Bank of Commerce was merged with the City National Bank, the merged institution becoming the City National Bank of Commerce under the charter of the City National Bank. Later the name of the merged bank was changed to the City National Bank. On May 23, 1921, a return was filed in the name of the…
2Cases cited7 opinions
- Keokuk & Western Railroad v. MissouriSupreme Court of the United States · 1894
- Central Railroad & Banking Co. v. GeorgiaSupreme Court of the United States · 1876
- Chicago Title & Trust Co. v. DoyleIllinois Supreme Court · 1913
- Fagan v. Texas Co.Court of Appeals of Texas · 1920
- First Nat. Bank of Tulsa, Okl. v. HooverCourt of Appeals of Texas · 1925
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3Cited by6 opinions
- Manufacturers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Manufacturers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- National Bank of Commerce v. CommissionerUnited States Board of Tax Appeals · 1930
- Park & Tilford v. CommissionerUnited States Board of Tax Appeals · 1941
- Sharpe v. CommissionerUnited States Board of Tax Appeals · 1938
1 more not listed; retrieve them via the Exa API.