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.
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