Indus. Valley Bank & Trust Co. v. Comm'r
United States Tax Court
Industrial Valley Bank & Trust Co. (IVB) entered into merger agreements with other banks (Lehigh and Doylestown). A few days prior to the actual mergers, IVB sold Lehigh and Doylestown substantial portions of its loan portfolio. Upon consummation of the mergers, the loans automatically returned to IVB as the survivor.
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Industrial Valley Bank & Trust Co. (IVB) entered into merger agreements with other banks (Lehigh and Doylestown). A few days prior to the actual mergers, IVB sold Lehigh and Doylestown substantial portions of its loan portfolio. Upon consummation of the mergers, the loans automatically returned to IVB as the survivor. IVB sought, on behalf of Lehigh and Doylestown, to obtain increased deductions for additions to their bad debt reserves for their final year, increasing their net operating losses and giving rise to loss carrybacks to earlier years. Both parties agreed that the availability of…
1Opinion of the Court
OPINION
Hall, Judge:
Respondent determined the following deficiencies for the following years:2
Sec. 6653(a) addition to tax Bank Lehigh Valley Trust Co. Doylestown Trust Co.. Year 1962 1963 1964 1965 1966 1967 1968 Deficiency $1,142.89 13.03 167.52 45,795.41 66,728.31 3,334.47 29,516.00 $2,289.77 3,336.42 166.72 1,476.00
This case was submitted fully stipulated under Rule 122. Concessions having been made by both parties, the questions remaining for determination are:(1) Whether respondent abused his discretion in denying Lehigh Valley Trust Co. and Doylestown Trust Co. certain additions to…
2Cases cited4 opinions
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- Conlorez Corp. v. CommissionerUnited States Tax Court · 1968
- Woodbury v. CommissionerUnited States Tax Court · 1967
- Merchants Industrial Bank, a Corporation Organized and Existing Under the Laws of the State of Colorado v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
3Cited by51 opinions
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Nico v. CommissionerUnited States Tax Court · 1977
- Sacks v. CommissionerUnited States Tax Court · 1994
- Van Roekel v. CommissionerUnited States Tax Court · 1989
- Blake v. CommissionerUnited States Tax Court · 1981
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