Central Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. A reply under Rule 15 is solely for the purpose of admitting or denying facts or of setting forth facts upon which the petitioner relies as a defense against the affirmative contentions made by the respondent; and it can not be used to raise new issues in which the petitioner seeks affirmative relief. 2. A national bank acquired part of the assets of a state bank, for cash and the assumption of part of the liabilities.
Read the full summary
1. A reply under Rule 15 is solely for the purpose of admitting or denying facts or of setting forth facts upon which the petitioner relies as a defense against the affirmative contentions made by the respondent; and it can not be used to raise new issues in which the petitioner seeks affirmative relief. 2. A national bank acquired part of the assets of a state bank, for cash and the assumption of part of the liabilities. The state bank discontinued business and withdrew from the state depositors' guaranty fund, which gave it the right to a refund based on its contributions, and part of this…
1Opinion of the Court
OPINION.
Murdock :
The Central National Bank is the petitioner at Docket No. 42587. The Commissioner determined a deficiency of $6,217.83 in its income tax for the period March 6 to December 31, 1925. The Central Trust & Savings Bank is the petitioner at Docket No. 42588. The Commissioner determined deficiencies of $2,403.67 and $4,062.90 in its income tax for the period March 6 to December 31, 1925, and for the calendar year 1926, respectively.
The Central National Bank in its petition assigns eight errors relating to the calendar year 1926. Since the Commissioner determined no deficiency in…
2Cases cited10 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Planters Cotton Oil Co. v. HopkinsSupreme Court of the United States · 1932
- Warner Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Frelmort Realty Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Gerber & Associates, Inc. v. CommissionerUnited States Tax Court · 1987
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
- Central Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.