Legal Opinion

Hatboro Nat'l Bank v. Commissioner

United States Tax Court

Decided July 28, 1955No. Docket No. 46155Published

Petitioner acquired real estate and other assets in 1930 as collateral for a loan. In 1936, pursuant to the instructions of the National Bank Examiner, petitioner's board of directors passed a resolution directing the transfer of the "loan" from the loans and discounts account to the other real estate account. In 1946 petitioner sold part of the real estate pledged as collateral.

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Petitioner acquired real estate and other assets in 1930 as collateral for a loan. In 1936, pursuant to the instructions of the National Bank Examiner, petitioner's board of directors passed a resolution directing the transfer of the "loan" from the loans and discounts account to the other real estate account. In 1946 petitioner sold part of the real estate pledged as collateral. Held, the real estate was held as collateral and petitioner did not realize a capital gain or loss on its sale. Held, further, in computing the proper additions to petitioner's reserve for bad debts for the years…

1Opinion of the Court

Hatboro National Bank, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hatboro Nat'l Bank v. Commissioner

Docket No. 46155

United States Tax Court

24 T.C. 786; 1955 U.S. Tax Ct. LEXIS 128;

July 28, 1955, Filed

Decision will be entered for the respondent.

Petitioner acquired real estate and other assets in 1930 as collateral for a loan. In 1936, pursuant to the instructions of the National Bank Examiner, petitioner's board of directors passed a resolution directing the transfer of the "loan" from the loans and discounts account to the other real estate account. In 1946 petitioner sold…

2Cases cited9 opinions

  1. Old Colony Trust Associates v. HassettCourt of Appeals for the First Circuit · 1945
  2. Jones v. CostlowSupreme Court of Pennsylvania · 1944
  3. Mayer Tank Mfg. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1942
  4. Thomas v. Waters Admr.Supreme Court of Pennsylvania · 1944
  5. Elverson Corporation v. HelveringCourt of Appeals for the Second Circuit · 1941

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