United States v. Seattle-First National Bank, 321 U.S. 583 (1944)

Contents:
Author: U.S. Supreme Court

Show Summary

United States v. Seattle-First National Bank, 321 U.S. 583 (1944)

Please note: this case begins in mid-page. It therefore shares a citation with the last page of the previous case. If you are attempting to follow a link to the last page of 321 U.S. 573, click here.

United States v. Seattle-First National Bank


No. 267


Argued February 7, 8, 1944
Decided March 27, 1944
321 U.S. 583

CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE NINTH CIRCUIT

Syllabus

Under authority of § 3 of the National Banking Act, as amended, and pursuant to a consolidation agreement, a state bank was consolidated in 1935 with a national banking association. The transfer to the consolidated association of title to the property of the state bank was not evidenced by deed, conveyance, assignment or other instrument.

Held:

1. In respect of (a) securities held by the state bank as legal and beneficial owner and (b) securities to which the state bank held legal title in fiduciary capacities, the transfer was "wholly by operation of law" within the meaning of Treasury Regulations 71 (1932 ed.), Arts. 34(r) and 35(r), and thereby exempt from the stamp tax imposed by § 800, Schedule A, pars. 3 and 9, of the Revenue Act of 1926, as amended. P. 588.

2. The transfer to the consolidated association of the realty of the state bank was not subject to the stamp tax imposed by § 800, Schedule A-8, of the Revenue Act of 1926, as amended, since the property was not conveyed by any "deed, instrument, or writing," was not "sold," and there was no "purchaser." P. 589.

136 F.2d 676 affirmed.

Certiorari, 320 U.S. 723, to review the affirmance of a judgment for the plaintiff, 44 F.Supp. 603, in a suit to recover sums paid as taxes.

Contents:

Related Resources

None available for this document.

Download Options


Title: United States v. Seattle-First National Bank, 321 U.S. 583 (1944)

Select an option:

*Note: A download may not start for up to 60 seconds.

Email Options


Title: United States v. Seattle-First National Bank, 321 U.S. 583 (1944)

Select an option:

Email addres:

*Note: It may take up to 60 seconds for for the email to be generated.

Chicago: U.S. Supreme Court, "Syllabus," United States v. Seattle-First National Bank, 321 U.S. 583 (1944) in 321 U.S. 583 321 U.S. 584. Original Sources, accessed August 14, 2022, http://www.originalsources.com/Document.aspx?DocID=3US31AKMCVI4BL3.

MLA: U.S. Supreme Court. "Syllabus." United States v. Seattle-First National Bank, 321 U.S. 583 (1944), in 321 U.S. 583, page 321 U.S. 584. Original Sources. 14 Aug. 2022. http://www.originalsources.com/Document.aspx?DocID=3US31AKMCVI4BL3.

Harvard: U.S. Supreme Court, 'Syllabus' in United States v. Seattle-First National Bank, 321 U.S. 583 (1944). cited in 1944, 321 U.S. 583, pp.321 U.S. 584. Original Sources, retrieved 14 August 2022, from http://www.originalsources.com/Document.aspx?DocID=3US31AKMCVI4BL3.