Crocker First Nat. Bank of San Francisco v. Commissioner of Internal Revenue

This appeal arises on a petition to review the decision and order of the United States Board of Tax Appeals affirming the determination by the Commissioner of Internal Revenue of a deficiency tax of $2,888.08 due from appellant for the year 1926. 22 B. T. A: 1159. The facts were stipulated by the parties and are as follows:

“1. In 1925 a merger of several banks was effected and the petitioner acquired certain banking premises situated on the. northwest comer of Montgomery and Post Streets, San Francisco. A part of the premises consisted of an annex which was in part a two-story and basement structure that had been erected shortly before 1925 with a foundation said to be about twenty feet .deep.

■ “2. During the calendar year 1926 an old building adjoining the bank’s two-story structure was razed and a new building of about twenty-five stories, known as the Hunter Du-lin Building, was erected. The Hunter Du-lin Building’s foundation' was about ten feet deeper than the petitioner’s annex on the side adjoining the new building. The local building regulations required that adjoining foundations extend down to the same level. Accordingly, a new brick foundation was placed below the…