Legal Opinion

City Bank of Washington v. Commissioner

United States Tax Court

Decided August 23, 1962No. Docket No. 90485Published

On May 29, 1959, the stockholders of City Bank adopted (1) a plan of complete liquidation and (2) a resolution approving the sale of City Bank's assets. The adoption of such plan culminated several months of activity during which representatives of both City Bank and the purchasers worked on the contemplated transaction and at all times material herein it was the intention of the purchasers, upon acquiring the requisite number of shares of stock, to liquidate City Bank.

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On May 29, 1959, the stockholders of City Bank adopted (1) a plan of complete liquidation and (2) a resolution approving the sale of City Bank's assets. The adoption of such plan culminated several months of activity during which representatives of both City Bank and the purchasers worked on the contemplated transaction and at all times material herein it was the intention of the purchasers, upon acquiring the requisite number of shares of stock, to liquidate City Bank. On May 26, 1959, City Bank, in anticipation of the adoption of a plan of liquidation, sold a portion of its Government…

1Opinion of the Court

The City Bank of Washington, Petitioner, v. Commissioner of Internal Revenue, Respondent

City Bank of Washington v. Commissioner

Docket No. 90485

United States Tax Court

38 T.C. 713; 1962 U.S. Tax Ct. LEXIS 92;

August 23, 1962, Filed

Decision will be entered under Rule 50.

On May 29, 1959, the stockholders of City Bank adopted (1) a plan of complete liquidation and (2) a resolution approving the sale of City Bank's assets. The adoption of such plan culminated several months of activity during which representatives of both City Bank and the purchasers worked on the contemplated transaction and at all…

2Cases cited5 opinions

  1. Mountain Water Co. v. CommissionerUnited States Tax Court · 1960
  2. Hawaiian Trust Company Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1961
  3. Virginia Ice & Freezing Corp. v. CommissionerUnited States Tax Court · 1958
  4. City Bank of Washington v. CommissionerUnited States Tax Court · 1962
  5. McDonald v. CommissionerUnited States Tax Court · 1961

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