Sugar Sales Corp. v. Loughman

The sole question is whether the petitioner had the right to deduct from its net income or profits all thereof except seven per cent on the par value of its capital stock, which right it claims under a contract in which the petitioner agrees to pay these several sums to the Royal Bank of Canada. The taxes computed on the net income for the four years, before the deduction is made, total $18,011.71; after the deduction the total is $509.08.

The petitioner is a domestic corporation, organized by or on behalf *350of the Royal Bank of Canada in 1913. This bank, or its nominees, held the entire capital…