Security Cent. Nat'l Bank v. Commissioner
United States Board of Tax Appeals
In the "merger" of a state bank under the charter of petitioner, a national bank, each bank contributed an agreed amount of the increased capital, surplus, and undivided profits of petitioner, and transferred its remaining assets to trustees, in trust, under terms whereby for a period of two years the petitioner could substitute bad assets for good assets placed in trust by the contributing bank.
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In the "merger" of a state bank under the charter of petitioner, a national bank, each bank contributed an agreed amount of the increased capital, surplus, and undivided profits of petitioner, and transferred its remaining assets to trustees, in trust, under terms whereby for a period of two years the petitioner could substitute bad assets for good assets placed in trust by the contributing bank. The new stock of petitioner was distributed among the stockholders of the respective banks according to the contributions made, and the trustees issued certificates to the old stockholders to…
1Opinion of the Court
*352OPINION.
Sea well :
Evidence was offered by the petitioner to prove that it sustained a loss of $42,379.79 under the Security Bank trust and a joint loss of $40,386.89 under both trusts. It also sought to prove that, in the alternative, it is entitled to a deduction of $41,388.32, the face amount of the notes substituted for cash and good assets, for bad debts. We have determined the gross income and deductions, including losses and bad debts, of the Central Bank trust to be the amounts claimed by the petitioner. No similar findings are necessary respecting the Security Bank trust under the…
2Cases cited8 opinions
- Ex Parte Worcester County National BankSupreme Court of the United States · 1929
- Zeller v. MilliganCalifornia Court of Appeal · 1925
- Commonwealth v. First National Bank & Trust Co.Supreme Court of Pennsylvania · 1931
- Hofheimer v. Seaboard Citizens National BankSupreme Court of Virginia · 1930
- Hofheimer v. Seaboard Citizens' National BankSupreme Court of Virginia · 1931
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Security Cent. Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1935