First Nat'l Bank v. Commissioner
United States Tax Court
P, a bank, sold a building in Albuquerque to a partnership in exchange for cash and a promissory note. Thereafter, Albuquerque issued metropolitan redevelopment bonds to finance acquisition and redevelopment of the building. P, along with a correspondent bank, purchased all of the bonds. The bond proceeds were deposited in an account maintained by P as trustee.
Read the full summary
P, a bank, sold a building in Albuquerque to a partnership in exchange for cash and a promissory note. Thereafter, Albuquerque issued metropolitan redevelopment bonds to finance acquisition and redevelopment of the building. P, along with a correspondent bank, purchased all of the bonds. The bond proceeds were deposited in an account maintained by P as trustee. P, as trustee of the bond proceeds account, then paid the face value of the promissory note to itself as noteholder. Held, P disposed of the promissory note at face value and must recognize gain on the note consistent with I.R.C.…
1Opinion of the Court
THE FIRST NATIONAL BANK IN ALBUQUERQUE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
First Nat'l Bank v. Commissioner
Docket No. 4878-86.
United States Tax Court
T.C. Memo 1988-516; 1988 Tax Ct. Memo LEXIS 542; 56 T.C.M. (CCH) 575; T.C.M. (RIA) 88516;
November 7, 1988.
P, a bank, sold a building in Albuquerque to a partnership in exchange for cash and a promissory note. Thereafter, Albuquerque issued metropolitan redevelopment bonds to finance acquisition and redevelopment of the building. P, along with a correspondent bank, purchased all of the bonds. The bond proceeds were deposited…
2Cases cited7 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Commissioner of Internal Revenue v. BlumCourt of Appeals for the Seventh Circuit · 1951
- Burrell Groves, Inc. v. CommissionerUnited States Tax Court · 1954
- Thos. Goggan & Bro. v. CommissionerUnited States Board of Tax Appeals · 1941
2 more not listed; retrieve them via the Exa API.