National Bank of Commerce v. Commissioner
United States Tax Court
Petitioner, a national banking corporation, in its regular course of business issued interest bearing nonnegotiable certificates of deposit which were not subject to check and with maturity dates of either 6 or 12 months. In its regular course of business petitioner accepted savings deposits evidenced by passbooks which deposits were not subject to check and the withdrawal of which petitioner required 60 days notice.
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Petitioner, a national banking corporation, in its regular course of business issued interest bearing nonnegotiable certificates of deposit which were not subject to check and with maturity dates of either 6 or 12 months. In its regular course of business petitioner accepted savings deposits evidenced by passbooks which deposits were not subject to check and the withdrawal of which petitioner required 60 days notice. Held, petitioner's outstanding indebtedness evidenced by the certificates of deposit and savings passbooks is not includible in borrowed capital under section 719 (a) (1) of the…
1Opinion of the Court
National Bank of Commerce, Petitioner, v. Commissioner of Internal Revenue, Respondent
National Bank of Commerce v. Commissioner
Docket No. 27771
United States Tax Court
16 T.C. 769; 1951 U.S. Tax Ct. LEXIS 226;
April 13, 1951, Promulgated
Decision will be entered for the respondent.
Petitioner, a national banking corporation, in its regular course of business issued interest bearing nonnegotiable certificates of deposit which were not subject to check and with maturity dates of either 6 or 12 months. In its regular course of business petitioner accepted savings deposits evidenced by passbooks which…
Also in this document: Dissent.
2Cases cited13 opinions
- Johnson v. Southern Pacific Co.Supreme Court of the United States · 1904
- Wetmore v. MarkoeSupreme Court of the United States · 1904
- Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
- Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
- West Constr. Co. v. CommissionerUnited States Tax Court · 1946
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