Wenn die FDIC für die ach so insolvente WMIH-R Steuer zahlen soll mhhhhhh...
IRS Memo released today - might be us?
« on: Today at 11:03:24 AM »
Quote jaysenese
Link:
www.irs.gov/pub/irs-wd/202126022.pdf"As of the date of this advice, FDIC continues to act as receiver. Although Taxpayer Bank did not file for title 11 bankruptcy protection, its parent holding company did."
I haven't read it yet.
« Reply
#1 on: Today at 11:18:23 AM »
Quote kenwalker
This Chief Counsel Advice responds to your request for assistance. Specifically, you have requested legal advice on how sections 6601, 6651(a)(2), and 6655 apply in the context of the section 7507(a) receivership of a specific bank.
Before I could even start reading:
Section 6601.--Interest on Underpayment, Nonpayment, or Extensions of Time for Payment
6651. Failure to file tax return or to pay tax
(2) to pay the amount shown as tax on any return specified in paragraph (1) on or before the date prescribed for payment of such tax (determined with regard to any extension of time for payment), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the amount shown as tax on such return 0.5 percent of the amount of such tax if the failure is for not more than 1 month, with an additional 0.5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate; or
6655. Failure By Corporation To Pay Estimated Income Tax
Sec. 7507. Exemption of insolvent banks from tax
(a) Assets in general
Whenever and after any bank or trust company, a substantial
portion of the business of which consists of receiving deposits and
making loans and discounts, has ceased to do business by reason of insolvency or bankruptcy, no tax shall be assessed or collected, or paid into the Treasury of the United States, on account of such bank or trust company, which shall diminish the assets there of
necessary for the full payment of all its depositors; and such tax
shall be abated from such national banks as are found by the
Comptroller of the Currency to be insolvent; and the Secretary,
when the facts shall appear to him, is authorized to remit so much of the said tax against any such insolvent banks and trust
companies organized under State law as shall be found to affect the claims of their depositors.
Quote kenwalker
Just skimmed it ( gotta go ) but it does look like us and it looks like we owe tax ............... and that's a good thing. It also looks like this is getting ready for a wind-up by FDIC.