Murphy v. Commissioner
United States Tax Court
1. Detroit Bankers was a holding corporation which owned no substantial assets except its stock in First National and certain other national banks. In 1933 First National, the other banks, and Detroit Bankers failed, and went into receiverships. In the same year a statutory assessment of 100 per cent was levied with respect to the stock of First National for which the petitioners, as stockholders of Detroit Bankers, were held to be proportionately liable.
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1. Detroit Bankers was a holding corporation which owned no substantial assets except its stock in First National and certain other national banks. In 1933 First National, the other banks, and Detroit Bankers failed, and went into receiverships. In the same year a statutory assessment of 100 per cent was levied with respect to the stock of First National for which the petitioners, as stockholders of Detroit Bankers, were held to be proportionately liable. In their income tax returns for 1933 the petitioners deducted as losses the cost of their stock in Detroit Bankers but derived no tax…
1Opinion of the Court
OPINION.
Withet, Judge:
While the record herein does not expressly show that Detroit Bankers was dissolved in 1933 and at the time of dissolution had no substantial assets, other than its bank stocks, the findings of the court in Barbour v. Thomas, 7 F. Supp. 271, affd. 86 F. 2d 510, certiorari denied 300 U. S. 670, in which the stockholders of Detroit Bankers were held proportionately liable for the assessment made on First National stock, are to that effect. In view of this, and since the parties have presented the instant proceedings on that theory, we will proceed upon such theory in…
2Cases cited9 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Hale v. HelveringCourt of Appeals for the D.C. Circuit · 1936
- Barbour v. ThomasCourt of Appeals for the Sixth Circuit · 1936
- Barbour v. ThomasDistrict Court, E.D. Michigan · 1933
4 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Black v. CommissionerUnited States Tax Court · 1960
- O'Brien v. CommissionerUnited States Tax Court · 1954
- Black v. CommissionerUnited States Tax Court · 1960
- Estate of Booth v. CommissionerUnited States Tax Court · 1954
- Merkel v. CommissionerUnited States Tax Court · 1954
3 more not listed; retrieve them via the Exa API.