Legal Opinion

Exchange State Bank v. Commissioner

United States Tax Court

Decided March 31, 1947No. Docket No. 7742Published

Losses resulting from the liquidation of segregated assets in a depositors' trust fund, held, not deductible against the taxable income of the bank from other sources, where the cost basis of the segregated assets had been returned to the bank in prior years through deductions claimed and allowed in its returns or in claims for refund.

1Opinion of the Court

Exchange State Bank, Petitioner, v. Commissioner of Internal Revenue, Respondent

Exchange State Bank v. Commissioner

Docket No. 7742

United States Tax Court

8 T.C. 721; 1947 U.S. Tax Ct. LEXIS 243;

March 31, 1947, Promulgated

Decision will be entered for the respondent.

Losses resulting from the liquidation of segregated assets in a depositors' trust fund, held, not deductible against the taxable income of the bank from other sources, where the cost basis of the segregated assets had been returned to the bank in prior years through deductions claimed and allowed in its returns or in claims for…

2Cases cited4 opinions

  1. Dobson v. CommissionerSupreme Court of the United States · 1944
  2. Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
  3. Bank of Newberry v. CommissionerUnited States Tax Court · 1942
  4. Exchange State Bank v. CommissionerUnited States Tax Court · 1947

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