Legal Opinion

Guaranty State Bank v. Commissioner

United States Board of Tax Appeals

Decided June 11, 1928No. Docket No. 5459Published

Findings made in 1922 by the State Banking Commissioner as to the financial condition of petitioner and the decree of the State court approving such report and declaring the bank insolvent are not res adjudicata of the questions involved here and certified copies thereof are not competent evidence to establish the invested capital of petitioner for 1920 and prior years, or to prove that petitioner is entitled to additional deductions in 1920 for bad debts which it had not in…

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Findings made in 1922 by the State Banking Commissioner as to the financial condition of petitioner and the decree of the State court approving such report and declaring the bank insolvent are not res adjudicata of the questions involved here and certified copies thereof are not competent evidence to establish the invested capital of petitioner for 1920 and prior years, or to prove that petitioner is entitled to additional deductions in 1920 for bad debts which it had not in that year ascertained to be worthless and charged off.

1Opinion of the Court

GUARANTY STATE BANK OF GREENVILLE, TEX., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Guaranty State Bank v. Commissioner

Docket No. 5459.

United States Board of Tax Appeals

12 B.T.A. 543; 1928 BTA LEXIS 3517;

June 11, 1928, Promulgated

Findings made in 1922 by the State Banking Commissioner as to the financial condition of petitioner and the decree of the State court approving such report and declaring the bank insolvent are not res adjudicata of the questions involved here and certified copies thereof are not competent evidence to establish the invested capital of petitioner for…

2Cases cited14 opinions

  1. Russell v. PlaceSupreme Court of the United States · 1877
  2. Oklahoma v. TextasSupreme Court of the United States · 1921
  3. Last Chance Mining Co. v. Tyler Mining Co.Supreme Court of the United States · 1895
  4. Mayor of Vicksburg v. HensonSupreme Court of the United States · 1913
  5. Washington, Alexandria, & Georgetown Steam-Packet Co. v. SicklesSupreme Court of the United States · 1861

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