Western Seattle National Financial of Seattle vmissioner off Internal Revenue, 288 F
The back ground in this situation should an effective the amount revolved in the applying of Area 332. In the Court’s opinion, that Section was not applicable.
Particular dispute could well be produced that the variety of interest stored from the depositor-investors was not a course out of stock for the concept of Area 332 which merger ranging from Movie industry and you can Domestic is the fresh merger away from a parent and you will an entirely-owned part. If you are instance results was it is possible to, this new Court feels one to once the, in fact, the business away from Movie industry proceeded in home instead of disturbance, the necessity for the fresh new reserve having money owed continued and did not quit and you can, thus, the new reserve should not be restored in order to income.
