United States v. Merchants Nat. Trust & Savings Bank

DENMAN, Circuit Judge.

This is an appeal from a judgment of the district court in favor of the appellee bank, the taxpayer, in the amount of $1,-019.37, with interest and costs, in an action brought by the taxpayer for a refund of a stamp tax assessed against and paid by it upon the transfer of the legal title to certain stocks and securities. These were held by taxpayer, a banking and trust company, as trustee of the many private trusts constituting its trust company business. That business and its trusts were sold to the Bank of America of California, also a banking corporation, in…