Alpena Sav. Bank v. Commissioner
United States Board of Tax Appeals
The petitioner bank was reorganized in the year 1933 in the following manner: Its depositors relinquished 50 percent of their deposits in consideration of receiving certificates of participation in the income and liquidation of specific assets which were set aside in a trust for their benefit.
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The petitioner bank was reorganized in the year 1933 in the following manner: Its depositors relinquished 50 percent of their deposits in consideration of receiving certificates of participation in the income and liquidation of specific assets which were set aside in a trust for their benefit. The bank then reopened free of all liability in respect of 50 percent of its deposits for which the depositors had received certificates of participation in the income and liquidation of the trust. All of the income of the trust accrued to the trust; all of the expenses of the trust, including taxes,…
1Opinion of the Court
*669OPINION.
Smith :
The respondent has determined deficiencies in income and excess profits taxes against petitioner for 1934. To the extent that the taxes are attributable to income in respect of its unsegregated assets, the petitioner now concedes liability; in other words, it concedes that it is liable for deficiencies in income and excess profits taxes for 1934 in the respective amounts of $310.33 and $112.85, which it claims already to halve paid.
The sole question in issue is whether the petitioner is liable to income tax for 1934 in respect of the income of a trust of segregated assets which…
2Cited by1 opinion
- Alpena Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1941