Moock Electric Supply Co. v. Commissioner
United States Board of Tax Appeals
Sale, for less than its face amount, of a participation certificate which represented a portion of petitioner's unpaid deposit in a closed bank, and which petitioner had received in a previous year under an agreement for reopening the bank, held, to justify a capital loss deduction in the year of sale, notwithstanding that both the face amount of the certificate and the price received upon the sale exceeded its value upon receipt.
1Opinion of the Court
*1210OPINION.
OppeR:
In 1931 The George D. Harter Bank of Cleveland, Ohio, closed its doors. In 1932 the bank reopened under an agreement of the type now familiar, whereby certain of its assets were segregated in a subsidiary corporation and depositors agreed to look to the latter for satisfaction of a portion of their claims. Petitioner, as a depositor in the bank, accepted the new arrangement and received for its $50,000 certificate of deposit in the bank a partially restricted deposit claim of 65 percent and a “certificate of participation” against the subsidiary corporation for the remaining 35…
2Cited by10 opinions
- Reed v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
- Sherman B. Harlan, Receiver for General Credit Corporation v. The United StatesUnited States Court of Claims · 1963
- Fairbanks, Morse & Co. v. HarrisonDistrict Court, N.D. Illinois · 1945
- Eljer Co. v. CommissionerCourt of Appeals for the Third Circuit · 1943
- Los Angeles Shipbuilding & Drydock Corp. v. United StatesDistrict Court, S.D. California · 1958
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