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FIDELITY-BALTIMORE NATIONAL BANK v. UNITED STATES

Civ. No. 11498.

213 F.Supp. 631 (1963)

FIDELITY-BALTIMORE NATIONAL BANK, a body corporate, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court D. Maryland.

February 6, 1963.

Attorney(s) appearing for the Case

George D. Hubbard, Semmes, Bowen & Semmes, Baltimore, Md., for plaintiff.

Bernard J. Schoenberg, Atty., Dept. of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Edward S. Smith, David A. Wilson, Jr., Attys., Dept. of Justice, Washington, D. C., and Joseph D. Tydings, U. S. Atty., Baltimore, Md.), on the brief, for defendant.

WINTER, District Judge.

As an incident to the corporate marriage of Baltimore National Bank, a national banking association (hereafter called "Baltimore"), and The Fidelity Trust Company, a Maryland chartered state bank (hereafter called "Fidelity"), the Commissioner of Internal Revenue determined that the resulting Fidelity-Baltimore National Bank & Trust Company (hereafter called "Fidelity-Baltimore"), was liable for original issue and documentary stamp tax...

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