Peoples Bank v. Commissioner
United States Board of Tax Appeals
Petitioner, a banking institution, closed its doors in May 1932 and in order to make possible its reopening its depositors relinquished and canceled one-half their deposits. Petitioner's stockholders agreed by separate contract with these depositors that these relinquished deposits would be paid before the stockholders claimed any dividends. The bank reopened in December 1932. In 1936 petitioner's stockholders paid $15,897.64 pro rata on the canceled deposits.
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Petitioner, a banking institution, closed its doors in May 1932 and in order to make possible its reopening its depositors relinquished and canceled one-half their deposits. Petitioner's stockholders agreed by separate contract with these depositors that these relinquished deposits would be paid before the stockholders claimed any dividends. The bank reopened in December 1932. In 1936 petitioner's stockholders paid $15,897.64 pro rata on the canceled deposits. Held, petitioner is not given immunity from collection of United States taxes by section 3798 of the Internal Revenue Code, since no…
1Opinion of the Court
THE PEOPLES BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Peoples Bank v. Commissioner
Docket No. 97143.
United States Board of Tax Appeals
43 B.T.A. 589; 1941 BTA LEXIS 1478;
February 13, 1941, Promulgated
Petitioner, a banking institution, closed its doors in May 1932 and in order to make possible its reopening its depositors relinquished and canceled one-half their deposits. Petitioner's stockholders agreed by separate contract with these depositors that these relinquished deposits would be paid before the stockholders claimed any dividends. The bank reopened in December…
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