Metrocorp, Inc. v. Commissioner

116 T.C. No. 18

UNITED STATES TAX COURT METROCORP, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19780-98. Filed April 13, 2001. 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…