Legal Opinion

Alpena Sav. Bank v. Commissioner

United States Board of Tax Appeals

Decided November 12, 1941No. Docket No. 89273Published

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

ALPENA SAVINGS BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Alpena Sav. Bank v. Commissioner

Docket No. 89273.

United States Board of Tax Appeals

45 B.T.A. 665; 1941 BTA LEXIS 1086;

November 12, 1941, Promulgated

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…

2Cases cited5 opinions

  1. West Town State Bank v. CommissionerUnited States Board of Tax Appeals · 1935
  2. Republic Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Valuation Service Co. v. CommissionerUnited States Board of Tax Appeals · 1940
  4. Alpena Sav. Bank v. CommissionerUnited States Board of Tax Appeals · 1941
  5. Alpena Savings Bank v. CommissionerUnited States Board of Tax Appeals · 1941

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