Philadelphia Saving Fund Society v. United States

KALODNER, Circuit Judge.

Plaintiff taxpayer brought this action to obtain a refund of federal income taxes paid with respect to its taxable year 1952. The facts being stipulated, both parties filed motions for summary judgment. The District Court entered judgment, via its Order, for the United States, 1 and the taxpayer took this appeal.

The issue presented for determination is whether the District Court erred in its holding that a credit received by the taxpayer, a mutual savings bank, from the Federal Deposit Insurance Corporation in 1952, when the taxpayer first became subject to federal…