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FIRST NATIONAL STATE BANK OF NEW JERSEY v. C.I.R.

Docket No. 3495-66.

51 T.C. 419 (1968)

FIRST NATIONAL STATE BANK OF NEW JERSEY (FORMERLY NATIONAL STATE BANK OF NEWARK, N.J.), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 18, 1968.

Attorney(s) appearing for the Case

Myles J. Sachs, for the petitioner.

Leo A. Burgoyne and Barry N. Mosebach, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for the calendar years 1958 and 1959 in the amounts of $96,180.29 and $46,967.49, respectively.

The issue for decision is the proper basis to petitioner under the provisions of section 334(b)(2), I.R.C. 1954,1 of assets received by it upon liquidation of a subsidiary.

All of the facts have been stipulated and are found accordingly...

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