FIRST NATIONAL BANK v. COMMISSIONER

Docket No. 1522-63.

24 T.C.M. 1597 (1965)

T.C. Memo. 1965-286

First National Bank in Walsenburg, Transferee v. Commissioner.

United States Tax Court.

Filed October 28, 1965.


Attorney(s) appearing for the Case

Gene W. Reardon, First Nat'l Bank Bldg., Philadelphia, Pa., for the petitioner. Leo K. O'Brien, for the respondent.


Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent asserted liability against petitioner as transferee of The First State Bank of Walsenburg (hereinafter referred to as State) for the year ending December 31, 1955 and the taxable period from January 26 to November 30, 1958 of $3,985.70 and $1,710.90, respectively. The bases for these assertions were: (a) Allocation of a net operating loss of $16,087.21 incurred by State during the period...

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