Grand Rapids Nat'l Bank v. Commissioner
United States Board of Tax Appeals
Two banks were affiliated for the period January 1, 1922, to March 14, 1922, and on the latter date they merged under the National Bank Act and continued as one bank throughout the remainder of the year. Held that but one return was required.
1Opinion of the Court
*1121OPINION.
Siefkin :
The question presented for our consideration is whether two affiliated corporations, which merged during the year 1922, must file two returns, one for the period of affiliation and one for the period of merger or, whether one return for the entire period is proper.
The position of the petitioner is that the merger did not create a new corporate entity; that since no new corporate entity was created, no new taxable entity would result, since the two corporations which were the basis of the merger were affiliated prior to the merger and that, therefore, only one taxable entity…
2Cited by4 opinions
- Manufacturers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Central Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933
- Grand Rapids Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1928
- Manufacturers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933