Exchange State Bank v. Commissioner
United States Tax Court
Losses resulting from the liquidation of segregated assets in a depositors' trust fund, held, not deductible against the taxable income of the bank from other sources, where the cost basis of the segregated assets had been returned to the bank in prior years through deductions claimed and allowed in its returns or in claims for refund.
1Opinion of the Court
OPINION.
LeMire, Judge:
This proceeding involves income tax deficiencies for the years 1941, 1942, and 1943 in the respective amounts of $375.91, $974.21, and $135.21. The only question in issue is whether the petitioner, a state bank, is entitled to deduct losses resulting from the operation of a depositors’ trust fund. The respondent disallowed the deductions on the ground that the cost basis of the segregated assets had been exhausted by loss deductions claimed and allowed in the petitioner’s returns for prior years. The petitioner contends that the cost basis of such assets should be…
2Cases cited3 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
- Bank of Newberry v. CommissionerUnited States Tax Court · 1942
3Cited by5 opinions
- Robinson v. CommissionerUnited States Tax Court · 1949
- Robinson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Sellers v. CommissionerUnited States Tax Court · 1977
- Exchange State Bank v. CommissionerUnited States Tax Court · 1947
- Robinson v. CommissionerUnited States Tax Court · 1949