Manufacturers Trust Co. v. Commissioner
United States Board of Tax Appeals
The petitioner, a national banking association, was consolidated with the Metropolitan National Bank on March 15, 1925, and the consolidated association continued under the charter of the petitioner.
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The petitioner, a national banking association, was consolidated with the Metropolitan National Bank on March 15, 1925, and the consolidated association continued under the charter of the petitioner. Thereafter, the petitioner reported in a single return for the calendar year 1925 its own income and deductions for the period January 1 to March 15, 1925, also the income and deductions of the Metropolitan Bank for the same period, and the income and deductions of the consolidated association for the remainder of the year. Held, that the single return filed by the petitioner improperly included…
1Opinion of the Court
*1262OPINION.
Trammell :
The issue in this case is whether or not the respondent erred in refusing to allow the petitioner to deduct from its gross income for the year 1925 the sum of $36,991,17, representing the *1263statutory net loss sustained by the Metropolitan National Bank & Trust Co. for the period January 1 to March 15, 1925. The Metropolitan Bank was merged or consolidated with the petitioner on the latter date, under the Act of Congress approved November 7, 1918 (40 Stat. 1043, 12 U.S.C.A., secs. 33, 34), and the consolidated bank continued under the petitioner’s charter.
The petitioner…
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3Cited by1 opinion
- Manufacturers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933