Riggs Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Where one corporation, which owns all of the stock of a second corporation, causes the second corporation to be dissolved, and takes over its assets, which have a value less than the cost of the stock, the first corporation has a deductible loss which it may claim in computing its income for the period following affiliation.
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1. Where one corporation, which owns all of the stock of a second corporation, causes the second corporation to be dissolved, and takes over its assets, which have a value less than the cost of the stock, the first corporation has a deductible loss which it may claim in computing its income for the period following affiliation. Remington Rand, Inc. v. Commissioner, 33 Fed.(2d) 77, followed; Farmers Deposit National Bank,5 B.T.A. 520; Interurban Construction Co.,5 B.T.A. 529; H. S. Crocker Co.,5 B.T.A. 537, distinguished. 2. In computing the deductible loss, adjustment must be made for…
1Opinion of the Court
*617OriNION.
Phillips:
There is no dispute between the parties as to the cost to petitioner of the stock of the Hamilton Savings Bank nor is there any dispute as to the value of the assets of that bank taken over by the petitioner, other than good will. It is urged on behalf of the Commissioner that, in addition to the other assets of the Hamilton Savings Bank, the petitioner acquired the good will of that bank and that such good will had value. The record contains much testimony with respect to the losses of the Savings Bank, the character of its loans and investments, its relations to its…
2Cases cited2 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Goodrich v. EdwardsSupreme Court of the United States · 1921
3Cited by19 opinions
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Frelmort Realty Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- RJ Reynolds Tobacco Co. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1938
- Summerfield Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Albert Leon & Son, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933
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