Legal Opinion

Nat'l Bank of Commerce v. Commissioner

United States Board of Tax Appeals

Decided June 9, 1939No. Docket No. 89720Published

1. In 1933 six small banks, almost all of the stock of which was held by a bank holding company, transferred all of their assets to petitioner, a larger bank also controlled by the holding company, pursuant to a plan of reorganization looking to the operation of the transferor banks as branches of petitioner, the transferee bank.

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1. In 1933 six small banks, almost all of the stock of which was held by a bank holding company, transferred all of their assets to petitioner, a larger bank also controlled by the holding company, pursuant to a plan of reorganization looking to the operation of the transferor banks as branches of petitioner, the transferee bank. Preliminary to the transfers all of the banks charged off their books not only worthless debts but also debts which had value but might be subject to criticism by banking authorities. Petitioner assumed the liabilities of the transferor banks, which liabilities were…

1Opinion of the Court

THE NATIONAL BANK OF COMMERCE OF SEATTLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Nat'l Bank of Commerce v. Commissioner

Docket No. 89720.

United States Board of Tax Appeals

40 B.T.A. 72; 1939 BTA LEXIS 903;

June 9, 1939, Promulgated

1. In 1933 six small banks, almost all of the stock of which was held by a bank holding company, transferred all of their assets to petitioner, a larger bank also controlled by the holding company, pursuant to a plan of reorganization looking to the operation of the transferor banks as branches of petitioner, the transferee bank. Preliminary to the…

2Cases cited11 opinions

  1. Avery v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1927
  2. Block v. CommissionerUnited States Board of Tax Appeals · 1939
  3. Darling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1931
  4. Nat'l Bank of Commerce v. CommissionerUnited States Board of Tax Appeals · 1939
  5. Central Loan & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1939

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