Bankers Trust Co. v. United States

This action to recover corporate income taxes assessed and paid was brought on behalf of the Mesabi Trust by its trustees, as successor to the Mesabi Iron Company. The taxes were assessed as a deficiency in the Mesabi Company’s 1960 return, and all relevant events occurred prior to the July 18, 1961 change to trust status. The company rather than the trust and trustees will be referred to as “Mesabi,” “the taxpayer,” and “plaintiff.”

The disputed tax, amounting to $3,016,182.64 plus interest, arises from a difference between plaintiff and the Internal Eevenue Service as to the value of 163,570…