NATIONAL BANK OF COMMERCE OF SEATTLE v. COMMISSIONER

Docket No. 56324.

27 T.C. 762 (1957)

THE NATIONAL BANK OF COMMERCE OF SEATTLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 8, 1957.


Attorney(s) appearing for the Case

R. A. Moen, Esq., for the petitioner.

John H. Welch, Esq., for the respondent.


OPINION.

ATKINS, Judge:

The respondent determined a deficiency in the petitioner's income tax for the calendar year 1950 in the amount of $12,581.13, of which amount $3,506.90 is in dispute. The question presented is whether, in computing the petitioner's excess profits credit based on income, the income experience of 4 banks whose assets were acquired by the petitioner in 1948 and early 1950 should be taken into account. The facts were stipulated...

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