Central Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. A reply under Rule 15 is solely for the purpose of admitting or denying facts or of setting forth facts upon which the petitioner relies as a defense against the affirmative contentions made by the respondent; and it can not be used to raise new issues in which the petitioner seeks affirmative relief. 2. A national bank acquired part of the assets of a state bank, for cash and the assumption of part of the liabilities.
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1. A reply under Rule 15 is solely for the purpose of admitting or denying facts or of setting forth facts upon which the petitioner relies as a defense against the affirmative contentions made by the respondent; and it can not be used to raise new issues in which the petitioner seeks affirmative relief. 2. A national bank acquired part of the assets of a state bank, for cash and the assumption of part of the liabilities. The state bank discontinued business and withdrew from the state depositors' guaranty fund, which gave it the right to a refund based on its contributions, and part of this…
1Opinion of the Court
CENTRAL NATIONAL BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
CENTRAL TRUST & SAVINGS BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Central Nat'l Bank v. Commissioner
Docket Nos. 42587, 42588.
United States Board of Tax Appeals
29 B.T.A. 530; 1933 BTA LEXIS 921;
December 14, 1933, Promulgated
1. A reply under Rule 15 is solely for the purpose of admitting or denying facts or of setting forth facts upon which the petitioner relies as a defense against the affirmative contentions made by the respondent; and it can not be used to raise new issues in which the…
2Cases cited1 opinion
- Central Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933