Legal Opinion

First Nat. Bank in Houston v. Scofield, Collector of Internal Revenue

Court of Appeals for the First Circuit

Decided January 29, 1953No. 14180PublishedCited by 2 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

The appellant, First National Bank in Houston, brought this action against the appellee, Collector of Internal Revenue, to recover allegedly excessive income taxes paid for the year 1944. The appellant, hereinafter! referred to as the taxpayer, was organized and began business in 1933. During the years 1931 to 1935, the taxpayer’s predecessor, First National Bank of Houston, charged off as worthless bad debts certain securities without realizing any tax benefit therefrom. Amid various transactions over the years, these securities were acquired by the taxpayer from its…

2Cases cited6 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Commissioner of Internal Revenue v. Moline Properties, Inc.Court of Appeals for the Fifth Circuit · 1942
  4. Weber Flour Mills Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1936
  5. Brandon Corporation v. COMMISSIONER OF INT. REVENUECourt of Appeals for the Fourth Circuit · 1934

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3Cited by2 opinions

  1. Ridge Realization Corp. v. CommissionerUnited States Tax Court · 1966
  2. Ridge Realization Corp. v. CommissionerUnited States Tax Court · 1966

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