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WEST SEATTLE NATIONAL BANK OF SEATTLE v. COMMISSIONER

Docket No. 74361.

33 T.C. 341 (1959)

WEST SEATTLE NATIONAL BANK OF SEATTLE, A NATIONAL BANKING ASSOCIATION IN VOLUNTARY LIQUIDATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 27, 1959.

Attorney(s) appearing for the Case

R. A. Moen, Esq., and E. S. McCord, Esq., for the petitioner.

George E. Constable, Esq., and Harris J. Nuernberg, Esq., for the respondent.

OPINION.

DRENNEN, Judge:

Respondent determined a deficiency in petitioner's income tax for the taxable period January 1, 1956, to May 28, 1956, in the amount of $6,417.58.

The single issue involved is whether when petitioner sold its banking business as a going concern on January 27, 1956, and, pursuant to a preadopted plan of complete liquidation, dissolved on May 28, 1956, the balance in its reserve for bad debts at the time the assets,...

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