SOUTHERN BANCORPORATION, INC., Plaintiff-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.
United States Court of Appeals, Fourth Circuit.https://leagle.com/images/logo.png
Argued January 4, 1988.
Decided May 16, 1988.
Attorney(s) appearing for the Case
Robert Harold Hishon (William R. Asbell, Jr., Hishon & Ranney, Atlanta, Ga., on brief), for plaintiff-appellant.
Jonathan S. Cohen, Tax Div., U.S. Dept. of Justice (Michael C. Durney, Acting Asst. Atty. Gen., Michael C. Paup, Francis M. Allegra, Tax Div., Dept. of Justice, Washington, D.C., on brief), for defendant-appellee.
Before RUSSELL and CHAPMAN, Circuit Judges, and BUTZNER, Senior Circuit Judge.
United States Court of Appeals, Fourth Circuit.
CHAPMAN, Circuit Judge:
Southern Bancorporation, Inc. ("Southern")1 appeals the December 31, 1986 decision of the United States Tax Court holding that the premium paid to the Federal Deposit Insurance Corporation ("FDIC") for the acquisition of certain assets and the assumption of certain liabilities of American Bank and Trust Company ("American"), a failing bank, is not amortizable. The Tax Court also held that Southern's claim is collaterally...
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