Washington State Bank v. Commissioner

Board of Tax Appeals

Washington State Bank v. Commissioner

20 B.T.A. 33, 1930 BTA LEXIS 2213

CourtUnited States Board of Tax Appeals

DecidedJune 12, 1930

DocketDocket No. 19911.

StatusPublished

Cited by1 cases

This text of 20 B.T.A. 33 (Washington State Bank v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Washington State Bank v. Commissioner, 20 B.T.A. 33, 1930 BTA LEXIS 2213 (bta 1930).

Pincite

Opinion

[35]*35OPINION.

Matthews:

The petitioner contends that in order to prevent ill effects to itself which might result from the failure of another state bank in the same town, it paid, in purchasing the assets of that bank and assuming its liabilities, $40,000 more than the assets received were worth; and upon this theory seeks to deduct this amount as an expense incident to the transaction, apportioning it over a two-year period.

Our interpretation of the transaction is that the petitioner purchased the going business of the Bank of Clallam County for $821,372.41 and assumed liabilities of the bank in that amount. The fact that the petitioner paid more for the assets than they were worth is not the basis for a deduction.

Judgment will be entered for the respondent.

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