National Bank of Commerce v. Commissioner
United States Tax Court
Excess Profits Credit -- Purchasing Corporation. -- The petitioner, in 1948 and early 1950, purchased substantially all the properties of 4 State banks, the principal part of the consideration for which was the assumption by the petitioner of the deposit liabilities of the State banks, but in three instances part of the consideration was the payment of cash by the petitioner.
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Excess Profits Credit -- Purchasing Corporation. -- The petitioner, in 1948 and early 1950, purchased substantially all the properties of 4 State banks, the principal part of the consideration for which was the assumption by the petitioner of the deposit liabilities of the State banks, but in three instances part of the consideration was the payment of cash by the petitioner. Held, that the petitioner, for purposes of computing its excess profits credit based on income for the year 1950, is entitled, under section 474, I. R. C. 1939, to compute its average base period net income by taking…
1Opinion of the Court
The National Bank of Commerce of Seattle, Petitioner, v. Commissioner of Internal Revenue, Respondent
National Bank of Commerce v. Commissioner
Docket No. 56324
United States Tax Court
27 T.C. 762; 1957 U.S. Tax Ct. LEXIS 267;
February 8, 1957, Filed
Decision will be entered under Rule 50.
Excess Profits Credit -- Purchasing Corporation. -- The petitioner, in 1948 and early 1950, purchased substantially all the properties of 4 State banks, the principal part of the consideration for which was the assumption by the petitioner of the deposit liabilities of the State banks, but in three instances part…
2Cases cited1 opinion
- National Bank of Commerce v. CommissionerUnited States Tax Court · 1957