- 10 -
9,665,713 shares of its common stock for the stock of DBTC (other
than fractional shares and shares with respect to which
dissenter's appraisal rights were exercised and for which $33,341
was paid) and then receiving all the stock of New Davenport in
exchange for the stock of DBTC.
Following the transaction, New Davenport carried on a
banking business. New Davenport's main office was the same
office as DBTC's, and New Davenport's branches were at the four
locations at which DBTC had formerly operated (not including the
main office) and at each of the three locations at which BBNA had
formerly operated (including the location that had been BBNA’s
main office). New Davenport offered a wider array of products
and services than DBTC had offered before the transaction and
continued DBTC’s tradition of being a charitable and community
leader.
DBTC's board and management anticipated that the transaction
would produce significant long-term benefits for DBTC and its
shareholders, among others.
3. Costs Incurred by DBTC in 1991
During 1991, DBTC paid L&W $474,018 for services rendered
($460,000) and disbursements made ($14,018) during the year.
DBTC deducted the $474,018 on its 1991 Federal income tax return.
Petitioner concedes that DBTC's $474,018 deduction was
improper, alleging that the deduction should have been $111,270.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011