Legal Opinion

Crocker First Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided October 4, 1932No. Docket No. 39874Published

1. Held that the Crocker First National Bank of San Francisco is the transferee of the assets of the First National Bank of San Francisco and that the Board has jurisdiction to determine its liability for the taxes of the latter company for the years 1924 and 1925. 2. Held that since the deficiency notice is not a notice to the other two petitioners, the Board does not have jurisdiction of the proceeding in so far as it relates to them. 3. Claimed deduction for loss on…

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1. Held that the Crocker First National Bank of San Francisco is the transferee of the assets of the First National Bank of San Francisco and that the Board has jurisdiction to determine its liability for the taxes of the latter company for the years 1924 and 1925. 2. Held that since the deficiency notice is not a notice to the other two petitioners, the Board does not have jurisdiction of the proceeding in so far as it relates to them. 3. Claimed deduction for loss on stocks denied for lack of evidence to establish worthlessness thereof. 4. The action of the respondent, in determining net…

1Opinion of the Court

CROCKER FIRST NATIONAL BANK OF SAN FRANCISCO (SUCCESSOR), FIRST FEDERAL TRUST COMPANY, AND EAST WATERWAY DOCK & WAREHOUSE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Crocker First Nat'l Bank v. Commissioner

Docket No. 39874.

United States Board of Tax Appeals

26 B.T.A. 1078; 1932 BTA LEXIS 1190;

October 4, 1932, Promulgated

1. Held that the Crocker First National Bank of San Francisco is the transferee of the assets of the First National Bank of San Francisco and that the Board has jurisdiction to determine its liability for the taxes of the latter company for the years…

2Cases cited1 opinion

  1. Crocker First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1932

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