Crocker First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Held that the Crocker First National Bank of San Francisco is the transferee of the assets of the First National Bank of San Francisco and that the Board has jurisdiction to determine its liability for the taxes of the latter company for the years 1924 and 1925. 2. Held that since the deficiency notice is not a notice to the other two petitioners, the Board does not have jurisdiction of the proceeding in so far as it relates to them. 3. Claimed deduction for loss on…
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1. Held that the Crocker First National Bank of San Francisco is the transferee of the assets of the First National Bank of San Francisco and that the Board has jurisdiction to determine its liability for the taxes of the latter company for the years 1924 and 1925. 2. Held that since the deficiency notice is not a notice to the other two petitioners, the Board does not have jurisdiction of the proceeding in so far as it relates to them. 3. Claimed deduction for loss on stocks denied for lack of evidence to establish worthlessness thereof. 4. The action of the respondent, in determining net…
1Opinion of the Court
*1083OPINION.
McMahon:
The petitioners in this case are the First Federal Trust Company, the East Waterway Dock & Warehouse Company and the Crocker First National Bank of San Francisco, a successor to the First National Bank of San Francisco. The First National Bank, the First Federal Trust Company, the East Waterway Dock & Warehouse Company and the Rogers Brown Transportation Company filed a consolidated return for the year 1923. For the years 1924 and 1925 the First Federal Trust Company filed individual returns and the other three filed consolidated returns. The respondent, however, ruled that…
2Cases cited4 opinions
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Denman v. SlaytonSupreme Court of the United States · 1931
- First Nat. Bank of Chicago v. United StatesSupreme Court of the United States · 1931
3Cited by5 opinions
- Aagaard v. CommissionerUnited States Tax Court · 1971
- Wilson Furs, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933
- Aagaard v. CommissionerUnited States Tax Court · 1971
- Crocker First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1932
- Wilson Furs, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933