Southern Bancorporation, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
1Opinion of the Court
CHAPMAN, Circuit Judge:
Southern Bancorporation, Inc. (“Southern”) 1 appeals the December 81, 1986 decision of the United States Tax Court holding that the premium paid to the Federal Deposit Insurance Corporation (“FDIC”) for the acquisition of certain assets and the assumption of certain liabilities of American Bank and Trust Company (“American”), a failing bank, is not amortizable. The Tax Court also held that Southern’s claim is collaterally estopped by this court’s decision in Southern Bancorporation, Inc. v. United States, 732 F.2d 374 (4th Cir.1984), ce rt. denied, 469 U.S. 1207, 105…
2Cases cited11 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
- United States v. Stauffer Chemical Co.Supreme Court of the United States · 1984
- Jerome H. Moore and Mildred v. Moore v. United States of America, Jerome H. Moore and Mildred v. Moore v. United StatesCourt of Appeals for the Fourth Circuit · 1966
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
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- Colorado National Bankshares, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1993
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