Legal Opinion

First Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided January 30, 1941No. Docket No. 101772Published

After default of a note secured by shares, the lender took the shares into its asset account at their fair market value and charged off as worthless the amount of the loan in excess of such value. For computing gain on the subsequent sale of the shares, basis held to be their value when taken over.

1Opinion of the Court

THE FIRST NATIONAL BANK, PHILIPSBURG, PENNSYLVANIA, PETITIONER, v. Commissioner of Internal Revenue, Respondent.

First Nat'l Bank v. Commissioner

Docket No. 101772.

United States Board of Tax Appeals

43 B.T.A. 456; 1941 BTA LEXIS 1501;

January 30, 1941, Promulgated

After default of a note secured by shares, the lender took the shares into its asset account at their fair market value and charged off as worthless the amount of the loan in excess of such value. For computing gain on the subsequent sale of the shares, basis held to be their value when taken over.

Lawrence Cake, Esq., for the petitioner.

P…

2Cases cited1 opinion

  1. First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1941

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