Banc One Corp. v. Commissioner
United States Tax Court
P acquired two banks at prices exceeding the aggregate book values of the assets reported in the financial statements of the acquired banks. Held, petitioner is not precluded from allocating the aggregate purchase prices among the acquired assets even though such allocations were not negotiated or calculated at the time of the acquisitions.
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P acquired two banks at prices exceeding the aggregate book values of the assets reported in the financial statements of the acquired banks. Held, petitioner is not precluded from allocating the aggregate purchase prices among the acquired assets even though such allocations were not negotiated or calculated at the time of the acquisitions. Held, further, depreciation deductions claimed by P with respect to a "loan premium" denied because P failed to establish basis in excess of book value for the loans. Held, further, P is not entitled to depreciation deductions with respect to core deposits…
1Opinion of the Court
Banc One Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Banc One Corp. v. Commissioner
Docket No. 10756-80
United States Tax Court
84 T.C. 476; 1985 U.S. Tax Ct. LEXIS 102; 84 T.C. No. 35;
March 28, 1985. March 28, 1985, Filed
Decision will be entered under Rule 155. 12
P acquired two banks at prices exceeding the aggregate book values of the assets reported in the financial statements of the acquired banks. Held, petitioner is not precluded from allocating the aggregate purchase prices among the acquired assets even though such allocations were not negotiated or calculated…
2Cases cited49 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- Metropolitan Bank v. St. Louis Dispatch Co.Supreme Court of the United States · 1893
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
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