Citizens Trust Co. v. Commissioner
United States Board of Tax Appeals
Organization expenses of a state bank held not deductible as a loss when such bank was merged with another bank under the laws of the State of New York.
1Opinion of the Court
*393OPINION.
Seawell:
What is here contended is that since the amounts expended in connection with the organization of the Citizens Trust Co. were capital items which could not be exhausted-over the life of the corporation (Hershey Manufacturing Co., 14 B. T. A. 867), the cost of such capital items constituted a deductible loss to the Citizens Trust Co. when such company was merged with the Marine Trust Co. on December 15, 1923. The facts are very meager as to what occurred in such merger, the only information we have being that “ the Citizens Trust Co. was absorbed by merger, under the Banking…
2Cases cited3 opinions
- In Re Proving the Will of BergdorfNew York Court of Appeals · 1912
- Bank of Long Island v. YoungAppellate Division of the Supreme Court of the State of New York · 1905
- In re Proving the Last Will & Testament of BergdorfAppellate Division of the Supreme Court of the State of New York · 1912
3Cited by10 opinions
- Vulcan Materials Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Kingsford Co. v. CommissionerUnited States Tax Court · 1964
- Koppers Company, Inc., Successor on Merger to Koppers Company, Transferee of Koppers Building, Inc., Transferor v. United StatesUnited States Court of Claims · 1960
- Maier Brewing Co. v. CommissionerUnited States Tax Court · 1987
- Addressograph-Multigraph Corp. v. Comm'rUnited States Tax Court · 1945
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