First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
Held, under the circumstances as shown, it is not established that the petitioner received, during the years involved, the tax-exempt income in controversy.
1Opinion of the Court
*747OPINION.
Lansdon:
The petitioner claims that the several amounts added to its gross income by the respondent for each of the years involved represented tax-exempt income derived by it from interest on Federal, state and municipal securities acquired and held by it under the circumstances set forth in the findings of fact.
*748At the outset it is clear that the transactions involving the year 1922 must be eliminated from our consideration, since there is nothing definite in the record to show what deals, if any, were carried on during that year to which the repurchase contract, in evidence, might…
2Cases cited3 opinions
- Peugh v. DavisSupreme Court of the United States · 1878
- Russell v. SouthardSupreme Court of the United States · 1851
- Jackson v. LawrenceSupreme Court of the United States · 1886
3Cited by3 opinions
- American National Bank of Austin v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- Bank of California, Nat'l Asso. v. CommissionerUnited States Board of Tax Appeals · 1934
- First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1930