Legal Opinion

Corona v. Commissioner

United States Tax Court

Decided July 16, 1992No. Docket No. 11391-90Unpublished

During the early 1980s, P owned shares of stock of a State chartered bank, a part of whose deposits were insured by the FDIC. The parties have stipulated that the bank was insolvent in 1984. For several years, including the year at issue (1984), the bank was subject to increasing scrutiny by both the State banking authorities and the FDIC.

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During the early 1980s, P owned shares of stock of a State chartered bank, a part of whose deposits were insured by the FDIC. The parties have stipulated that the bank was insolvent in 1984. For several years, including the year at issue (1984), the bank was subject to increasing scrutiny by both the State banking authorities and the FDIC. Those authorities took several regulatory actions against the bank and its officers and directors, requiring the correction of various unsafe or unsound banking practices. In 1986, the State authorities appointed the FDIC as liquidator of the bank, and it…

1Opinion of the Court

RAY L. CORONA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Corona v. Commissioner

Docket No. 11391-90

United States Tax Court

T.C. Memo 1992-406; 1992 Tax Ct. Memo LEXIS 426; 64 T.C.M. (CCH) 196;

July 16, 1992, Filed

Decision will be entered for respondent.

During the early 1980s, P owned shares of stock of a State chartered bank, a part of whose deposits were insured by the FDIC. The parties have stipulated that the bank was insolvent in 1984. For several years, including the year at issue (1984), the bank was subject to increasing scrutiny by both the State banking authorities and…

2Cases cited14 opinions

  1. Morton v. CommissionerUnited States Board of Tax Appeals · 1938
  2. Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
  3. Steadman v. Comm'rUnited States Tax Court · 1968
  4. De Loss v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1928
  5. Charles W. Steadman and Dorothy F. Steadman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970

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