Participation Holding Co. v. Commissioner

1 T.C. 852, 1943 U.S. Tax Ct. LEXIS 200
CourtUnited States Tax Court
DecidedMarch 30, 1943
DocketDocket No. 110245
StatusPublished
Cited by2 cases

This text of 1 T.C. 852 (Participation Holding Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Participation Holding Co. v. Commissioner, 1 T.C. 852, 1943 U.S. Tax Ct. LEXIS 200 (tax 1943).

Opinion

OPINION.

Disney, Judge:

The petitioner, in asking for exemption from collection of tax under section 818 of the Revenue Act of 1938, as amended by section 406 of the Revenue Act of 1939,1 of course has the burden of showing itself to be strictly within the statute. Cornell v. Coyne, 192 U. S. 418; Producers' Creamery Co. v. United States, 55 Fed. (2d) 104; Jockey Club, 30 B. T. A. 670; affd., 76 Fed. (2d) 597. Under the gist of the statute governing here, it must demonstrate, in order to secure the exemption, that the depositors had accepted, in lieu of deposits, claims against assets, segregated in the hands of an agent, and that such assets were available for payment of claims of depositors in the bank and necessary for the full payment thereof, and would be diminished by the imposition upon it as such agent of the tax here involved. Upon brief, the petitioner says:

Petitioner, standing by itself, might not be entitled to the immunity afforded by the statute since its primary creditors were holders of mortgage trust certificate issued by the Bank and were not depositors of the Bank.

The petitioner argues, however, that because of the interlocking relationship of petitioner and Fulton, created by the plan for reorganization of the bank, the immunity statute applies; because any residue left to Participation after discharge of its debentures would belong to Fulton and be subject to payment of its debentures held by the old depositors; further, that a tax on a wholly owned subsidiary of an insolvent bank is a tax on the bank, that there will be a residue of assets in the hands of petitioner for payment over to Fulton, and that the depositors of the bank will not be paid in full.

We have no hesitancy in holding that Participation comes within the definition of agent, as set forth in the amendment, section 406 (b), Eevenue Act of 1939. The situation in this respect is the same as in Valuation Service Co., 41 B. T. A. 811, in that the petitioner is owned by a corporation owned in turn by an insolvent bank. We there upheld the exemption.

After a detailed examination and consideration of the various instruments executed in pursuance of the plan, and particularly of the plan of reorganization itself, we come to the conclusion that the petitioner should be sustained in its view that any residue left in its hands after the discharge of the 5 percent registered participating debentures which it had issued, inured to the benefit of Fulton and to the benefit of those depositors who held Fulton’s 2 percent debenture notes in lieu of 70 percent of the deposits, and that therefore the depositors had a claim against assets transferred to Participation. That Fulton would get the benefit of any funds which might remain to Participation from the assets transferred to it to secure its debentures, after the discharge of its obligation of the holders of participating debentures, is inescapable since not only did Fulton have a contract to that effect, that is that it would receive such residuum as consideration for services rendered, but that in any event, by virtue of Fulton’s ownership of all the stock of Participation, the same result would accrue to Fulton. It is equally clear, we think, that any such residue, so coming to the hands of Fulton, was subject to the payment of Fulton’s 2 percent debenture notes, for the plan particularly provides that any cash realized by Fulton from its property and assets, whether by way of principal or income, and dividends received on the stock of the bank, might be applied, after certain other payments to be made, to the payment of the debenture notes. Moreover, although the bank held all the stock of Fulton, the stock of the bank in turn was in escrow with Fulton, and any dividends upon the bank’s stock (and the stock itself, in case of default on the notes at the end of seven years) were in turn to be applied to the payment of Fulton’s debenture notes. Thus it appears that any residuum received by Fulton from Participation could not inure to the benefit of its stockholders or to the benefit of the stockholders of the bank, the owner of Fulton’s stock, but must find its way into the payments to be made upon Fulton’s 2 percent debenture notes, since these were held by the former depositors as a substitute for TO percent of the old deposits. It is therefore plain that any residuum accruing to Participation after discharge of its own participating debentures was subjected to the payment of Fulton’s debenture notes to the depositors. That the other creditors of Fulton might also participate in the benefit, is immaterial. The Treasury takes that view: “The section is not for the relief of creditors other than depositors though it may incidentally operate for their benefit.” T.D. 4958, 1941 C. B., p. 74. The view is obviously sound, since nothing in-the act indicates that there is any exception to its general language merely because creditors other than depositors might participate in the benefit of immunity.

Although it is true, as the respondent argues, that neither Fulton’s 2 percent debenture note issue, nor Participation’s 5 percent registered participating debenture issue had any lien on, or charge upon, the assets of the other; that is not the complete answer to our question. For, if, regardless of whether Participation’s debenture holders had any lien or charge against Fulton or its assets securing its debenture notes, Participation should, in fact, have a residue left, after discharging its debentures, to which residue Fulton had a right, the question then simply is: Is any such fund, in Fulton’s hands, subject to be'used to discharge the obligation of Fulton to the former depositors? We think, for the reasons above set forth that it clearly is, and that the “depositors have accepted * * * claims against assets * * * transferred * * * to a corporate trustee or agent” in the language of section 818. Peoples Bank, 43 B. T. A. 589, is not in point because therein no assets were segregated for the benefit of depositors, and they had no lien on future earnings of the bank, having accepted merely contractual rights against the bank’s stockholders.

Any assets of Participation must also, under the statute, be necessary for full payment of the depositors, and that question we must now decide. It presents no difficulty. Since the evidence shows that the parties are in agreement that Fulton’s 2 percent debenture notes were worth only about 50 percent of face value, it is apparent that full payment of the 70 percent of the deposits, coming necessarily from the payment of the 2 percent debenture notes issued by Fulton, would require any funds of Fulton coming from other sources, including the residuum in Participation’s hands, and that such residuum, therefore, would be “necessary for the full payment” of the 70 percent depositors.

We must decide, therefore, in the final analysis,,whether the facts of record herein show that there was in fact in petitioner’s hands any such residuum. If such assets appear, it follows,that payment of the tax by petitioner would diminish such assets. The respondent contends that the evidence is that no residue will be due Fulton, but on the contrary the holders of Participation’s participating debentures will not be paid in full. Those participating debentures were issued to holders of mortgage trust certificates, not to any depositors of the old bant as such.

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Related

Farmers State Bank v. Commissioner
4 T.C.M. 94 (U.S. Tax Court, 1945)
Participation Holding Co. v. Commissioner
1 T.C. 852 (U.S. Tax Court, 1943)

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Bluebook (online)
1 T.C. 852, 1943 U.S. Tax Ct. LEXIS 200, Counsel Stack Legal Research, https://law.counselstack.com/opinion/participation-holding-co-v-commissioner-tax-1943.