EXCHANGE STATE BANK v. COMMISSIONER

Docket No. 7742.

8 T.C. 721 (1947)

EXCHANGE STATE BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 31, 1947.


Attorney(s) appearing for the Case

Harry E. Judd, Esq., for the petitioner.

Richard A. Jennings, Esq., for the respondent.


OPINION.

LEMIRE, Judge:

This proceeding involves income tax deficiencies for the years 1941, 1942, and 1943 in the respective amounts of $375.91, $974.21, and $135.21. The only question in issue is whether the petitioner, a state bank, is entitled to deduct losses resulting from the operation of a depositors' trust fund. The respondent disallowed the deductions on the ground that the cost basis of the segregated assets had been exhausted by loss deductions...

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