City Nat. Bank v. Commissioner of Internal Revenue

BRYAN, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals, which held the City National Bank of Wichita Palls, Tex., liable, as transferee of the assets of the National Bank of Commerce, for a deficiency in the income tax of ,the latter for that part of the year 1920 ending April 30, when the two hanks were consolidated under the provisions of the Act of Congress of November 7, 1918, 40 Stat. 1043 (12 USCA §§ 33, 34). The opinion of the Board is reported in 19 B. T. A. 1080.

After the consolidation business was continued in the name of the City National Bank and…