United States v. Seattle-First Nat. Bank

HEALY, Circuit Judge.

The question presented here is whether a statutory consolidation of banks under the National Bank Act, 12 U.S.C.A. § 34a, involves liability for documentary stamp tax under § 800 and Schedules A-3, A-8, and A-9, Title VIII, Revenue Act of 1926, as amended, 26 U.S.C.A. Int.Rev.Acts, pages 284, 289, 297.

In 1935 a state bank, the Spokane and Eastern Trust Company, consolidated with the First National Bank of Seattle under the name of Seattle-First National Bank. Upon the ratification of the consolidation agreement by the stockholders the comptroller of the currency issued…