Campbell County State Bank, Inc. v. Commissioner
United States Tax Court
1. The stockholders of a bank formed a partnership to engage in the insurance business, rather than use their bank for that purpose, because State law forbade banks to engage in other than banking activities. The partnership did engage in the insurance business. Held, the bank corporation and the insurance partnership are separate entities for Federal income tax purposes.
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1. The stockholders of a bank formed a partnership to engage in the insurance business, rather than use their bank for that purpose, because State law forbade banks to engage in other than banking activities. The partnership did engage in the insurance business. Held, the bank corporation and the insurance partnership are separate entities for Federal income tax purposes. Held, further, respondent may not, under section 482 of the Internal Revenue Code of 1954, disregard the separate existence of the insurance partnership by allocating to the bank all of the partnership's "net" income. 2.…
1Opinion of the Court
TeaiN, Judge:
Respondent determined deficiencies in income taxes of petitioner as follows:
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The issues are:(1) Whether respondent correctly determined that the income of the Herreid Insurance Agency is taxable to the Campbell County State Bank, Inc.; and(2) If not, whether respondent correctly determined that certain amounts deducted by the Campbell County State Bank, Inc., are properly deductions of the Herreid Insurance Agency and, if so, what those amounts should be.
BINDINGS OP PACT.
Some of the facts have been stipulated and are hereby found as stipulated.
Petitioner Campbell…
2Cases cited17 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
12 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- Ballentine Motor Co. v. CommissionerUnited States Tax Court · 1962
- Local Finance Corp. v. CommissionerUnited States Tax Court · 1967
- Campbell County State Bank, Incorporated, of Herreid, South Dakota v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Spicer Theatre, Inc. v. CommissionerUnited States Tax Court · 1964
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