Merchants Nat'l Bldg. Corp. v. Commissioner
United States Board of Tax Appeals
The X securities corporation was organized by a national bank for the purpose of carrying on types of business which it could not engage in directly. The stockholders of the bank were beneficial owners of the stock of X. X also owned and managed the bank premises.
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The X securities corporation was organized by a national bank for the purpose of carrying on types of business which it could not engage in directly. The stockholders of the bank were beneficial owners of the stock of X. X also owned and managed the bank premises. By reason of provisions of the Banking Act of 1933 it was deemed impossible for X, an affiliate of the bank, to continue in the general securities business, and in May 1934 X transferred all of its assets other than the bank premises to the bank, as trustee, for liquidation and ultimate distribution to its stockholders. X thereupon…
1Opinion of the Court
MERCHANTS NATIONAL BUILDING CORPORATION, FORMERLY MERCHANTS SECURITIES CORPORATION, THE MERCHANTS NATIONAL BANK OF MOBILE, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Merchants Nat'l Bldg. Corp. v. Commissioner
Docket Nos. 99181, 102155.
United States Board of Tax Appeals
45 B.T.A. 417; 1941 BTA LEXIS 1124;
October 22, 1941, Promulgated
The X securities corporation was organized by a national bank for the purpose of carrying on types of business which it could not engage in directly. The stockholders of the bank were beneficial owners of the stock of X. X also owned and…
2Cases cited4 opinions
- Taylor Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Caswell v. CommissionerUnited States Board of Tax Appeals · 1937
- Northwest Utilities Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Fidelity Nat'l Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1938