Legal Opinion

Federation Bank & Trust Co. v. Commissioner

United States Tax Court

Decided March 18, 1957No. Docket No. 59697Published

Petitioner bank was closed by the State Superintendent of Banks on October 30, 1931, and it reopened in 1932 after most of the depositors waived one-third of their deposits, under a plan whereby the depositors received certificates entitling them to share in the proceeds of the liquidation of designated assets.

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Petitioner bank was closed by the State Superintendent of Banks on October 30, 1931, and it reopened in 1932 after most of the depositors waived one-third of their deposits, under a plan whereby the depositors received certificates entitling them to share in the proceeds of the liquidation of designated assets. Under the plan the petitioner was to receive the first $ 5,530,036.25 of the proceeds of liquidation and a trustee for the certificate holders the balance up to $ 2,528,461.02. In 1942 petitioner had not recovered its senior interest, but it extinguished the junior interest of the…

1Opinion of the Court

Federation Bank & Trust Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Federation Bank & Trust Co. v. Commissioner

Docket No. 59697

United States Tax Court

27 T.C. 960; 1957 U.S. Tax Ct. LEXIS 240;

March 18, 1957, Filed

Decision will be entered under Rule 50.

Petitioner bank was closed by the State Superintendent of Banks on October 30, 1931, and it reopened in 1932 after most of the depositors waived one-third of their deposits, under a plan whereby the depositors received certificates entitling them to share in the proceeds of the liquidation of designated assets. Under the…

2Cases cited6 opinions

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Helvering v. American Chicle Co.Supreme Court of the United States · 1934
  3. Great Island Holding Corp. v. CommissionerUnited States Tax Court · 1945
  4. Marks v. CommissionerUnited States Tax Court · 1956
  5. Mutual Ben. Health & Accident Ass'n v. CrowderMississippi Supreme Court · 1947

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