PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 4

                                          4                                           
          1120 of the UFB Group for the calendar years 1990 through 1994              
          were prepared using the accrual method of accounting.                       
               At all times material, FNBP and UFSB were Federally                    
          chartered banks that were actively engaged in the banking                   
          business.                                                                   
               Petitioner is a bank holding company organized as a                    
          corporation under the laws of Delaware.  Petitioner's principal             
          place of business was located in Delaware at the time it filed              
          the petitions in these cases.4  On or about July 23, 1992, FNPC             
          was merged into petitioner.  On or about January 21, 1994, UFB              
          was merged into petitioner.  By virtue of these mergers,                    
          petitioner succeeded by operation of law to the assets and                  
          liabilities of FNPC and UFB.  Petitioner is a transferee at law             
          of assets of FNPC and UFB and as such would be liable under                 
          section 6901 for any deficiencies in Federal income tax                     
          determined to be owing by FNPC and UFB for the years at issue.              
               The principal businesses of FNBP and UFSB (collectively                
          referred to as the banks) consisted of accepting demand and time            
          deposits and using the amounts deposited, together with other               


               4The petitions filed in docket Nos. 16002-95 and 16003-95              
          were filed by petitioner in response to a notice of deficiency              
          (in the case of docket No. 16002-95) and a notice of liability              
          (in the case of docket No. 16003-95) sent to petitioner in its              
          respective capacities as successor in interest to First National            
          Pennsylvania Corp. (FNPC) and as transferee of assets of FNPC.              
          The petitions filed in docket Nos. 16109-96 and 16110-96 were               
          filed by petitioner in response to a notice of deficiency (in the           
          case of docket No. 16109-96) and a notice of liability (in the              
          case of docket No. 16110-96) sent to petitioner in its respective           
          capacities as successor in interest to United Federal Bancorp,              
          Inc. and Subs. (UFB) and as transferee of assets of UFB.                    


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