The taxpayer was able to convince the court that the creditors who got the stock in the reorganization were not the prior owners. Because the events occurred in 1992, under a prior version of the continuity of proprietary interest rules, continuity of ownership was broken and a section 338(h)(10) election could be made and the basis in the assets inside the corporation stepped up to fair market value, with no tax liability because the seller was in bankruptcy with large net operating losses (NOLs).
On Friday, the Washington Department of Financial Institutions closed North County Bank, headquartered in Arlington, Washington, and appointed the FDIC as receiver. As receiver, the FDIC entered into a purchase and assumption agreement with Whidbey Island Bank, headquartered in Coupeville, Washington, to assume all of the deposits of the failed bank.
On Friday, the Washington Department of Financial Institutions closed The Cowlitz Bank, headquartered in Longview, Washington and appointed the FDIC as receiver.
On Friday, the Office of Thrift Supervision closed Mainstreet Savings Bank, FSB, headquartered in Hastings Michigan, and appointed the FDIC [http://www.fdic.gov/bank/individual/failed/mainstsvgs.html] as receiver for the bank.
On Friday, the Florida Office of Financial Regulation closed three bank subsidiaries of Bank of Florida Corporation: (1) Bank of Florida – Southeast, Fort Lauderdale, Florida; (2) Bank of Florida – Southwest, Naples, Florida; and (3) Bank of Florida –
Yesterday, the Michigan Office of Financial and Insurance Regulation closed CF Bancorp, headquartered in Port Huron, Michigan, and the FDIC was appointed receiver. As receiver, the FDIC entered into a purchase and assumption agreement with First Michigan Bank, headquartered in Troy, Michigan, to assume all of the deposits of CF Bancorp.
On Friday, OTS closed Waterfield Bank, headquartered in Germantown, Maryland and appointed the FDIC as receiver. As receiver, the FDIC created Waterfield Bank, FA, a new depository institution chartered by the OTS and insured by the FDIC, to take over the operations of Waterfield Bank. The new institution will remain open until April 5, 2010, “to allow depositors access to their insured funds and time to move accounts to other insured institutions.”
On Friday, the Florida Office of Financial Regulation closed Florida Community Bank , headquartered in Immokalee, Florida and the FDIC was named receiver. As receiver, the FDIC entered into a purchase and assumption agreement with Premier American Bank, National Association, headquartered in Miami, Florida, to assume all of the deposits of Florida Community Bank.
On Friday, the Michigan Office of Financial and Insurance Regulation closed Citizens State Bank, headquartered in New Baltimore, Michigan, and the FDIC was named as receiver.