Legal Opinion

Commissioner of Internal Revenue v. The Charleston Nat. Bank, Charleston, W. Va

Court of Appeals for the Fourth Circuit

Decided May 19, 1954No. 6755PublishedCited by 14 opinions

1Opinion of the Court

SOPER, Circuit Judge.

The question in this case is whether, as the Tax Court held (20 T.C. 253), the Charleston National Bank, in computing its income tax for the years 1944 and 1945, was entitled to deduct as ordinary and necessary business expenses under § 23(a) of the Internal Revenue Code, 26 U.S.C.A., certain premiums which it paid in those years on life insurance policies held by it as collateral security for monies loaned by it to the insured.

The taxpayer is a national banking institution with its office and place of business in the City of Charleston, West Virginia. Its federal income…

2Cases cited12 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Clark Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1938
  3. Colony Coal & Coke Corp. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1931
  4. Federal National Bank of Shawnee, Oklahoma v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
  5. Gauley Mt. Coal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1928

7 more not listed; retrieve them via the Exa API.

3Cited by14 opinions

  1. Schultz v. CommissionerUnited States Tax Court · 1968
  2. Mercantile Nat'l Bank v. CommissionerUnited States Tax Court · 1958
  3. Blaess v. CommissionerUnited States Tax Court · 1957
  4. Harrison v. CommissionerUnited States Tax Court · 1973
  5. United States v. John S. Mellinger and Sweeney J. Doehring, as Executors of the Estate of Mary Edith Giles, DeceasedCourt of Appeals for the Fifth Circuit · 1956

9 more not listed; retrieve them via the Exa API.

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