United States v. Commercial National Bank

DAWKINS, Sr., District Judge.

The briefs and arguments in these two cases cover a multitude of points, but reduced to simple terms, there are only two issues. First, was the alleged tax debtor required to seek review through the Tax Court of the Commissioner’s holding that the sum involved, $462,269.83, was income, or can it be properly determined by this court? The total sum left after liquidation of the old bank, and the end of the litigation, was in excess of $800,000 and was paid to the Comptroller through his administratively appointed receiver. From this without consulting the court, the…