Legal Opinion

First Nat'l Bank v. Commissioner

United States Tax Court

Decided September 3, 1975No. Docket No. 3408-72Published

Petitioner, a national banking association, administers numerous trusts through its trust department. In administering the trusts, the said department makes cash payments on their behalf. Each cash payment is charged either to the principal or to the income account of the trust on behalf of which it is made.

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Petitioner, a national banking association, administers numerous trusts through its trust department. In administering the trusts, the said department makes cash payments on their behalf. Each cash payment is charged either to the principal or to the income account of the trust on behalf of which it is made. If a payment exceeds the balance in the account to be charged, the trust department may nonetheless make the payment, obtaining the funds necessary to cover the excess from petitioner's commercial loan department. Such a transaction is undertaken only if petitioner's responsible officers…

1Opinion of the Court

The First National Bank of Chicago, Petitioner v. Commissioner of Internal Revenue, Respondent

First Nat'l Bank v. Commissioner

Docket No. 3408-72

United States Tax Court

64 T.C. 1001; 1975 U.S. Tax Ct. LEXIS 72;

September 3, 1975, Filed

Decision will be entered under Rule 155.

Petitioner, a national banking association, administers numerous trusts through its trust department. In administering the trusts, the said department makes cash payments on their behalf. Each cash payment is charged either to the principal or to the income account of the trust on behalf of which it is made. If a payment…

2Cases cited9 opinions

  1. Commissioner v. ConnellySupreme Court of the United States · 1949
  2. First American National Bank of Nashville v. United StatesCourt of Appeals for the First Circuit · 1972
  3. Pullman Trust & Savings Bank v. United StatesDistrict Court, N.D. Illinois · 1963
  4. Pullman Trust & Savings Bank, an Illinois Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1964
  5. North Carolina National Bank v. The United StatesUnited States Court of Claims · 1965

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