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BANCO DI NAPOLI AGENCY IN NEW YORK v. COMMISSIONER

Docket Nos. 110979, 111558.

1 T.C. 8 (1942)

BANCO DI NAPOLI AGENCY IN NEW YORK, BY WILLIAM R. WHITE, SUPERINTENDENT OF BANKS OF THE STATE OF NEW YORK, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 12, 1942.

Attorney(s) appearing for the Case

R. C. Whitley, Esq., for the respondent.

OPINION.

MURDOCK, Judge.

The respondent has moved to dismiss these proceedings for lack of jurisdiction on the ground that the petition was filed after the appointment of a receiver for the taxpayer. The deficiency in each case was determined against Banco di Napoli Direzione Generale Napoli, and the notice of deficiency was sent to that taxpayer. The petition in each case was filed in 1942 by the Superintendent of Banks of the State of New York,...

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