Bank of America Nat'l Trust & Sav. Asso. v. Commissioner
United States Tax Court
Petitioner transferred legal title to eight of its banking premises to Capital Co. for a consideration which was less than the adjusted bases of the properties. Capital Co. was the wholly owned subsidiary of a holding company which owned a substantial interest in petitioner.
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Petitioner transferred legal title to eight of its banking premises to Capital Co. for a consideration which was less than the adjusted bases of the properties. Capital Co. was the wholly owned subsidiary of a holding company which owned a substantial interest in petitioner. Prior to the transfers, the parties agreed orally that title to the properties would be reconveyed on petitioner's command to petitioner, or to its wholly owned subsidiary, Merchants, in about 30 days for the same consideration as was originally advanced. During the time Capital Co. held title to the properties, it was…
1Opinion of the Court
Bank of America National Trust and Savings Association, Petitioner, v. Commissioner of Internal Revenue, Respondent
Bank of America Nat'l Trust & Sav. Asso. v. Commissioner
Docket No. 8993
United States Tax Court
15 T.C. 544; 1950 U.S. Tax Ct. LEXIS 58;
October 20, 1950, Promulgated
Decision will be entered under Rule 50.
Petitioner transferred legal title to eight of its banking premises to Capital Co. for a consideration which was less than the adjusted bases of the properties. Capital Co. was the wholly owned subsidiary of a holding company which owned a substantial interest in petitioner. Prior…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Weiss v. WeinerSupreme Court of the United States · 1929
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