Legal Opinion
West Seattle National Bank of Seattle v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 27, 1961No. 16838PublishedCited by 67 opinions
1Opinion of the Court
MERRILL, Circuit Judge.
This ease presents the question whether upon a sale of corporate assets pursuant to a plan of complete liquidation with the accounts receivable being sold at face value, the taxpayer’s reserve for bad debts constitutes ordinary income and is taxable as such or constitutes gain and is free from tax under § 337(a) of Internal Revenue Code of 1954, 26 U.S.C.A. § 337(a).
The taxpayer, an incorporated national banking association conducting a general banking business in Seattle, Washington, adopted a plan of complete liquidation on January 27, 1956. Pursuant to this plan, the…
2Cases cited5 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
- National Bank of Commerce v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1940
- Merchants Nat. Bank of Mobile v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
3Cited by67 opinions
- Louis Spitalny and Betty Spitalny, His Wife v. United States of America, William Erdwurm and Bart F. Erdwurm, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Commissioner of Internal Revenue v. D. B. AndersCourt of Appeals for the Tenth Circuit · 1969
- Mayfair Minerals, Inc. v. CommissionerUnited States Tax Court · 1971
- Commissioner of Internal Revenue v. South Lake Farms, Inc., Commissioner of Internal Revenue v. South Lake FarmsCourt of Appeals for the Ninth Circuit · 1963
- Frank E. Connery, in No. 19,432 v. United States of America. Max Kraven, in No. 19,433 v. United StatesCourt of Appeals for the Third Circuit · 1972
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