Fidelity Nat. Bank & Trust Co. of Kansas City v. Commissioner

BOOTH, Circuit Judge.

This is a petition to review a decision and order of the United States Board of Tax Appeals, which redetermined a deficiency in the ineome and profits tax for the year 1919 of the petitioner, the Fidelity National Bank & Trust Company, in the sum of $8,681.

The facts found by the Board of Tax Appeals are substantially as follows: Prior to May 1, 1919, the Fidelity Trust Company was a corporation under state law. On that date'it became a national bank under the name Fidelity National Bank & Trust Company. In the latter part of 1918, and the early part of 1919, negotiations…