Fidelity Nat'l Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
Two national banks were consolidated or merged under the amended charter of one of them and certain of their "excess" assets which were not taken over by the new bank were transferred to trustees for liquidation. The income of the trust was to be distributable annually or oftener and capital distributions were to be made at the discretion of the trustees.
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Two national banks were consolidated or merged under the amended charter of one of them and certain of their "excess" assets which were not taken over by the new bank were transferred to trustees for liquidation. The income of the trust was to be distributable annually or oftener and capital distributions were to be made at the discretion of the trustees. Held, that the trust so created was liquidating trust and not an association taxable as a corporation; held, further, that the income of the trust was distributable annually and was therefore deductible by the trust and taxable to the…
1Opinion of the Court
FIDELITY NATIONAL BANK AND TRUST COMPANY, ALLEGED TO BE AN ASSOCIATION TAXABLE AS A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FIDELITY NATIONAL BANK AND TRUST COMPANY OF KANSAS CITY, A NATIONAL BANKING ASSOCIATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
HENRY C. FLOWER, LESTER W. HALL AND W. D. JOHNSON, TRUSTEES FOR STOCKHOLDERS OF FIDELITY NATIONAL BANK AND TRUST COMPANY OF KANSAS CITY OF RECORD, DECEMBER 31, 1928, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fidelity Nat'l Bank & Trust Co. v. Commissioner
Docket Nos. 85644,…
2Cases cited1 opinion
- Fidelity Nat'l Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1938