Commissioner v. Hagerman

DAVIS, Circuit Judge.

Prior to 1933, the taxpayer, Stanley Hagerman, acquired certain shares of stock of the First National Bank of the City of New York, hereinafter referred to as the bank. The stock of the bank, pursuant to a prior agreement entered into by all of the stockholders, carried with it, as evidenced by an endorsement thereon, a ratable interest in the First Security Company, the "security affiliate" of the bank. Due to certain provisions in the "Banking Act of 1933", 48 Stat. 162, the Security Company was dissolved and its asset~ were transferred to a trustee. The taxpayer, and…