Metrocorp, Inc. v. Commissioner
United States Tax Court
M, a State bank, acquired a portion of the assets and assumed a portion of the deposit liabilities of C, a failed Federal savings association. Before the transaction, the deposit liabilities of M and C were insured by different funds (B and S, respectively) administered by the Federal Deposit Insurance Corporation.
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M, a State bank, acquired a portion of the assets and assumed a portion of the deposit liabilities of C, a failed Federal savings association. Before the transaction, the deposit liabilities of M and C were insured by different funds (B and S, respectively) administered by the Federal Deposit Insurance Corporation. The transaction was a "conversion transaction" under 12 U.S.C. sec. 1815(d)(2)(B) (1994), because M and C each participated in a different fund, and M assumed C's deposit liabilities. R determined that the exit and entrance fees related to the transaction which M paid to S and B,…
1Opinion of the Court
METROCORP, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Metrocorp, Inc. v. Commissioner
No. 19780-98
United States Tax Court
116 T.C. 211; 2001 U.S. Tax Ct. LEXIS 18; 116 T.C. No. 18;
April 13, 2001, Filed
RUWE, WHALEN, and GALE, JJ., agree with this dissenting opinion.
M, a State bank, acquired a portion of the assets and
assumed a portion of the deposit liabilities of C, a failed
Federal savings association. Before the transaction, the deposit
liabilities of M and C were insured by different funds (B and S,
respectively) administered by the Federal Deposit Insurance
Corporation. The…
2Cases cited57 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- United States v. Winstar Corp.Supreme Court of the United States · 1996
- Lebron v. National Railroad Passenger CorporationSupreme Court of the United States · 1995
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