Fidelity-Baltimore National Bank v. United States

WINTER, District Judge.

As an incident to the corporate marriage of Baltimore National Bank, a national banking association (hereafter called “Baltimore”), and The Fidelity Trust Company, a Maryland chartered state bank (hereafter called “Fidelity”), the Commissioner of Internal Revenue determined that the resulting Fidelity-Baltimore National Bank & Trust Company (hereafter called “Fidelity-Baltimore”), was liable for original issue and documentary stamp tax for shares of Fidelity-Baltimore issued to shareholders of Baltimore and Fidelity. Fidelity-Baltimore paid the taxes, filed timely…