First Nat'l Corp. v. Commissioner
United States Tax Court
1. Petitioner and four banks, all of the stock of which it owned, were members of an affiliated group of corporations. The F bank, also a member of this group, desired to acquire the four banks so that it might operate them as branches. On April 2, 1933, petitioner gave the F bank proxies to vote the stock of the four banks and the F bank took over their assets and assumed their liabilities on the following day.
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1. Petitioner and four banks, all of the stock of which it owned, were members of an affiliated group of corporations. The F bank, also a member of this group, desired to acquire the four banks so that it might operate them as branches. On April 2, 1933, petitioner gave the F bank proxies to vote the stock of the four banks and the F bank took over their assets and assumed their liabilities on the following day. Thereafter negotiations were carried on with reference to the price to be paid. They culminated in the execution of five contracts on April 18, 1933, under the terms of which…
1Opinion of the Court
The First National Corporation of Portland, a Corporation, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent
First Nat'l Corp. v. Commissioner
Docket Nos. 108224, 108305, 108367, 108306, 109642, 109643, 109644, 109645
United States Tax Court
2 T.C. 549; 1943 U.S. Tax Ct. LEXIS 85;
August 12, 1943, Promulgated
Decision will be entered under Rule 50.
1. Petitioner and four banks, all of the stock of which it owned, were members of an affiliated group of corporations. The F bank, also a member of this group, desired to acquire the four banks so that it might operate them as…
2Cases cited1 opinion
- First Nat'l Corp. v. CommissionerUnited States Tax Court · 1943