Legal Opinion

Merchants Nat'l Bank v. Commissioner

United States Tax Court

Decided June 30, 1950No. Docket No. 20461Published

1. Petitioner, a national bank, was required by the Banking Act of 1933 to terminate, by June 16, 1934, its affiliation with a corporation dealing in securities. In May, 1934, assets of the affiliate, including shares of stock of a corporation, were transferred to petitioner as trustee, and about three years later the stock was transferred to petitioner as a commercial banking institution.

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1. Petitioner, a national bank, was required by the Banking Act of 1933 to terminate, by June 16, 1934, its affiliation with a corporation dealing in securities. In May, 1934, assets of the affiliate, including shares of stock of a corporation, were transferred to petitioner as trustee, and about three years later the stock was transferred to petitioner as a commercial banking institution. Held, that the loss sustained on the stock upon the liquidation of the corporation in 1943 was a long term capital loss. 2. In and prior to 1943 petitioner charged off with tax benefit the full amount of…

1Opinion of the Court

The Merchants National Bank of Mobile, Petitioner, v. Commissioner of Internal Revenue, Respondent

Merchants Nat'l Bank v. Commissioner

Docket No. 20461

United States Tax Court

14 T.C. 1375; 1950 U.S. Tax Ct. LEXIS 134;

June 30, 1950, Promulgated

Decision will be entered under Rule 50.

1. Petitioner, a national bank, was required by the Banking Act of 1933 to terminate, by June 16, 1934, its affiliation with a corporation dealing in securities. In May, 1934, assets of the affiliate, including shares of stock of a corporation, were transferred to petitioner as trustee, and about three years later the…

2Cases cited4 opinions

  1. Merchants Nat'l Bank v. CommissionerUnited States Tax Court · 1950
  2. Switlik v. CommissionerUnited States Tax Court · 1949
  3. Rockford Varnish Co. v. CommissionerUnited States Tax Court · 1947
  4. Rice Drug Co. v. CommissionerUnited States Tax Court · 1948

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